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Saturday, November 21, 2009

Save-A-Patriot Did Not Save a Doctor

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Yesterday, the Fifth Circuit decided a case, United States v. Miller , 588 F.3d 897 (5th Cir. 2009), here , sustaining a medical doctor'...
Friday, November 20, 2009

It's All About Interpretation

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This is a bit off topic, but I wanted to say something about it anyway. I just picked up this article, Mitchell N. Berman , Originalism Is ...
2 comments:

Is the Criminal Statute of Limitations Suspended under the Wartime Suspension Act? (11/20/09)

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There are rumors that the government in a tax shelter case is seeking to suspend the criminal statute of limitations under the "wartime...
1 comment:

Audit Avoidance as Tax Crimes Issue (11/20/09)

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Last night, I had my annual party for my current tax procedure class. We had a nice dinner with appropriate libations. We then settled into ...

Tax Perjury, § 7206(1), as Aggravated Felony for Immigration Purposes

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This morning a petition for certiorari caught my eye in reviewing Tax Notes Today and think it is an issue that Tax Crimes practitioners and...
1 comment:
Wednesday, November 18, 2009

United States and Swiss Confederation Release Criteria for Disclosing Names (11/18/09)

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This blog was updated on November 18, 2009 The criteria for the Swiss and UBS to apply in disclosing accounts held by U.S. persons is set ...
Tuesday, November 17, 2009

New Federal Task Force for Financial Crimes

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Today's news includes reports that the Federal Government will have yet another task force, this time to investigate and prosecute the f...

Swiss Release Criteria for Disclosing Names

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The reports are coming in that the Swiss have released the criteria for disclosing the approximately 4,450 names related to UBS accounts. I...

Lenient Sentencing in White Collar Crime / Tax Crime Cases (11/17/09)

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I have previously noted in this blog the lenient sentencing in the offshore financial account sentences to date (see here ). The concept of ...
2 comments:
Friday, November 13, 2009

Tax Shelters, Economic Substance and Tax Crimes (11/13/09)

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On November 10, the Fifth Circuit decided Enbridge Energy Company, Inc. v. United States , 2009 U.S. App. LEXIS 24713 (5th Cir. 2009) . The ...
Monday, November 9, 2009

DC Circuit Discusses Cost / Benefit Analysis for Tax Evasion (11/9/09)

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I have re-read an earlier case that I think may be interesting to readers of this blog. The case is Mayer Brown LLP v. IRS , 562 F.3d 1190 ...
Saturday, November 7, 2009

Recent Related Scholarship

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I picked up the following articles from a new blog called JOTTWELL that readers may finding interesting. JOTTWELL contains a summary of th...

Another UBS Client is Sentenced

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Press reports note that another UBS client was sentenced on 11/6. The highlights from the first I have seen, a Bloomberg report here . 1...
4 comments:

Unthinking Criminality - Where is the Line? (11/7/09)

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Thanks to the Tax Prof Blog , I picked up this article written by prolific tax lawyer and author, Robert W. Wood . The Article is "Ten ...
Tuesday, November 3, 2009

Duplicity in Government Charging of Evasion of Assessment Counts

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The Third Circuit issued an important opinion in United States v. Root, 585 F.3d 145 (3d Cir. 2009) . The major issue in the opinion is the ...
Sunday, November 1, 2009

For Students - Good Trial Multi Issue Opinion - Net Worth, Inconsistent verdicts etc.

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I offer the opinion in United States v. Matthew Fox, 2009 U.S. Dist. LEXIS 97638 (D. N.J. 2009) particularly for students in the tax crimes...
Saturday, October 31, 2009

Second UBS Client, Chernick, Sentenced (11/31/09)

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The press reports today proclaim the sentencing of Jeff Chernick on October 30. (See, e.g., the associated press article here .) The sentenc...
5 comments:
Thursday, October 29, 2009

First UBS Client, Rubinstein, Sentenced

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The New York Times Deal Book and other publications report today that the first UBS client to plead in the current round, Steven Michael Rub...