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Wednesday, April 29, 2009

Chipping Away at Potential 7202 Defenses

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On April 27, 2008, the Ninth Circuit issued a revised opinion in United States v. Easterday , ___ F.3d ___ (9th Cir. 2009) and denied petit...

Senate Passes Bill on Tax Crimes Money Laundering

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UPDATE AS OF MAY 26 2009: The House version of this bill did not include the expansion of money laundering for tax crimes and the House pre...
Monday, April 27, 2009

Get in Line Brother #5

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We have previously blogged here the Department of Justice initiative to squeeze UBS for its alleged illegal assistance to U.S. taxpayers...
Friday, April 24, 2009

May It Please the Court

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This New York Times presentation called May it Please the Court will make you feel good, particularly if you have been weighed down on tax ...

Tax Evasion to Money Laundering - Upping the Ante / Risk

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I just became aware of the petition for certiorari in the Yusuf case ( United States v. Yusuf , 536 F.3d 178 (3d Cir. 2008) , cert. pending...
Friday, April 17, 2009

Just In -- Another Big Loss for Big Brother in a Tax Case

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The Government's much ballyooed prosecution of Indy driver Castroneves has fizzled. See the article here . Perhaps are related read is t...

Major 3d Circuit En Banc Decision on Booker Sentencing in Tax Case (4/17/09)

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Thanks to the Doug Berman's Sentencing Law & Policy Blog , I learned of the Third Circuit's en banc decision in United States v....

Collateral Estoppel after Tax Evasion Conviction (4/17/09)

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The law is clear that, upon conviction for tax evasion, the taxpayer is estopped in the inevitable civil proceeding from asserting that civi...
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Thursday, April 16, 2009

Federal Prosecutors Feeling the Heat

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Persons practicing in the White Collar Crime area, including the federal tax crime area, have viewed with great interest the recent mutiple ...
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Tax Defiers - Is Texas Governor Perry One?

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Jonathan Turley this morning posted here a very interesting piece on Texas Governor Perry's rantings about Texas' right to secede f...
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Wednesday, April 15, 2009

Get in Line Brother & Righten That Wrong #4

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The IRS continues to press the offshore issue, using a tried and true technique -- the John Doe summons -- for gathering information from U....
Tuesday, April 14, 2009

Get in Line Brother & Righten That Wrong #3

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The bell tolls for another UBS Client: New York Times Article on Plea by Robert Moran, described as a wealthy UBS private banking client. W...

DOJ Tax Division Promo Piece on 2008 Accomplishments

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On April 13, 2008, DOJ Tax issued a self-promotion press release its accomplishements in 2008. Much of the release is related to criminal pr...
Monday, April 13, 2009

TIGTA Report of IRS Enforcement Activities for FYE 2000 - 2008

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TIGTA has produced its annual report on IRS Enforcement Activites. The report is here and the highlight report is here . The report prese...

Josephberg #2 - Fifth Amendment on Ongoing Returns During Criminal Investigation

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This is the second blog on the Josephberg case. Please refer to my first blog here which has a statement of the facts. I repeat here onl...
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Saturday, April 11, 2009

Josephberg #1 - Tax Due and Owing (4/11/09)

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I will write a series of blogs on various aspects of the Second Circuit's decision in United States v. Josephberg , ___ F.3 ___ (2d Cir....
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Thursday, April 9, 2009

Shumacher Article on Boulware (4/9/09)

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Scott Schumacher, co-author of the Tax Crimes book in the Lexis-Nexis series , has published an article in Tax Notes discussing the Ninth Ci...
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Get in Line Brother & Righten that Wrong #2

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Further on the indictment I mentioned here , Tax Notes has an article this morning on the indictment. The article makes it clear that the d...