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Wednesday, September 30, 2009

Summons Power to Force Summonsed Party to Gather Records from Third Parties (9/30/09)

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NOTE TO READERS - PLEASE SEE THE UPDATE AT THE END OF THIS BLOG In a recent summons enforcement case ( United States v. Bright , 2009 U.S....
8 comments:
Monday, September 28, 2009

DOJ Tax's Further Attempts to Drum Up Business / Revenue (12/26/09)

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Notice: This Blog will be supplemented from time to time as I receive reports of the occurrences at the ABA Tax Section that I feel worthy o...
10 comments:

Another UBS Related Plea Agreement (9/28/09)

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Juergen Homann pled guilty. The DOJ press release is here . The key points are: 1. The plea agreement is to one count of willful failure t...
1 comment:
Thursday, September 24, 2009

DOJ Tax Goes Wild for Girls Gone Wild Promoter

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On the eve of trial for tax evasion, Girls Gone Wild promoter, Joseph Francis, has pled guilty to two crimes. First, he pled to two counts...
Wednesday, September 23, 2009

Golf Pro Pleads Guilty to Tax Crime

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A plea announcement published in this morning’s Tax Notes Today (2009 TNT 182-26) grabbed my attention. On September 22, 2009, the U.S. Atto...
Monday, September 21, 2009

IRS Extends FBAR / Foreign Entity Relief Deadline to 10/15/09

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The IRS has extended to 10/15/09 the deadline for joining its special initiative voluntary disclosure practice with respect to foreign bank ...
3 comments:
Friday, September 18, 2009

Scalia on My Cousin Vinny

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I head off in about an hour to San Francisco for baby sitting chores for the weekend. Since I have been crunched lately with the voluntary d...
Thursday, September 10, 2009

Certainty of the Law's Command and Willfulness (9/10/09)

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In my last blog here, I concluded as follows: In this proposed instruction, the court pre-empts the issue of uncertainty in the law. Once ...
Tuesday, September 8, 2009

Uncertainty in the Law As a Defense in Tax Cases

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Recently, I posted a blog here on our firm’s sister site, Tax Controversy Update, which deals principally with the civil side of tax contro...
Wednesday, September 2, 2009

Confusion about the Defraud Conspiracy (9/2/09)

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Conspiracy is a frequent charge in tax related indictments. Indeed, Judge Easterbrook of the Seventh Circuit has lamented, with some hyperbo...

Get in Line Brother #25 - IRS Plans for Life After Voluntary Disclosure

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In an article in today's Tax Notes Today, David Stewart reports that the IRS is creating "a new group within its Large and Midsize ...
Monday, August 31, 2009

Reports of Death of Quiet Disclosure are an Exaggeration (8/31/09)

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The title of this blog, of course, is inspired by Samuel Clemens' dba Mark Twain comment: "The report of my death is an exaggerati...
Sunday, August 30, 2009

Get in Line Brother #24 - UBS Spin on Developments

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UBS has established its own web site here , presumably to make sure its spin on the developments gets told. I note, for example, that the do...
Saturday, August 29, 2009

Get in Line Brother #23 - States Want Their Pound of Flesh

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The Tax Prof Blog reports today here that the State of Connecticut is requesting the names of persons disclosed to the U.S. under the recen...

Ms. Sheppard's Article on the UBS Mess and its Permutations (8/29/09)

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Today's Tax Notes Today has an article by Lee Sheppard, a noted commentator on the tax law and fashions and movies and other esoterica a...
Thursday, August 27, 2009

Get In Line Brother #22 - New IRS FAQ on UBS Accounts

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On August 25, 2009, the IRS added a new FAQ to its FAQs on the voluntary disclosure initiative for foreign bank accounts. The FAQs as thus s...
Wednesday, August 26, 2009

IRS Administrative Processing of Restitution Payments (8/26/09)

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A recent Program Manager Technical Assistance (PMTA 2009-122, here ) addresses various issues on IRS processing of restitution payments to t...
4 comments:
Thursday, August 20, 2009

Swiss Bank Enablers Indicted

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Further ratcheting up the ante, DOJ obtained the indictment of a Swiss Banker and a Swiss Lawyer. The DOJ promo piece on the indictment is h...