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Sunday, February 27, 2011

Duke Snider Dies: A Great Baseball Player Who Made a Wrong Choice (2/27/11)

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The late 1940s and the 1950s were great times for baseball-- at least New York baseball. My brother, my cousin and I were New York baseball ...
Saturday, February 26, 2011

Barry Bonds Swings at the Obstruction Charge but Doesn't Hit This Time

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In United States v. Barry Lamar Bonds , 2011 U.S. Dist. LEXIS 15906 (ND CA 2011) , the third superseding indictment charged four counts of f...

Grand Juries Are Not for Trial Preparation After Indictment

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The Government properly uses grand juries to investigate and prepare cases for trial. But, what happens if the Government to continue using ...
1 comment:
Wednesday, February 23, 2011

More enablers indicted

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There is a new indictment out today here . The charge is one count of conspiracy. The individuals charged are: MARCO PARENTI ADAMI, EMANU...
5 comments:
Monday, February 21, 2011

Swiss Announcement that It will Continue to Drag Its Feet, but Marginally Less So (Perhaps), on Double Tax Treaty Administrative Assistance Requests

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The Swiss have announced a relaxed, perhaps, interpretation of their Double Tax Agreement ("DTA") Administrative Assistance provis...
8 comments:
Saturday, February 19, 2011

The "Slight Evidence" and Similar Formulations for Connection to a Conspiracy (2/19/11)

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In our Tax Fraud and Money Laundering Class last Monday,  Larry Campagna and I addressed conspiracy under Title 18 USC  § 371 . We covered...
1 comment:
Friday, February 18, 2011

Real World Dynamics -- the Cheek Good Faith Belief Defense

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In United States v. Mostler , 2011 U.S. App. LEXIS (3d Cir. 2/11/11) , an nonprecedential decision, the Court offers some real world dynamic...

TRAC November Statistics

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TRAC has November statistics for prosecutions and convictions of interest to readers of this blog: Prosecutions on cases referred by IRS ...

Posner and Yoon on What Judges Think of the Qualify of Legal Representation in Federal Criminal Cases

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I just reviewed Richard A. Posner and Albert H. Yoon, What Judges Think of the Quality of Legal Representation , 63 Stan. L. Rev. 317 (2011)...
Thursday, February 17, 2011

First Circuit Case on Relevant Conduct and Conditions of Supervised Release.

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In United States v. Thomas , 653 F.3d 13 (1st Cir. 2011), here , the defendant had a long history of failure to file, failure to pay, and va...
Saturday, February 12, 2011

Judge Smells a Rat in Government's Use of Tax Loss Presumption for Restitution

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The tax loss is the principal determinant in tax Guidelines sentencing calculations. The Guidelines "contemplate that the court will si...
1 comment:

Avoiding the Stipulations in a Plea Agreement for Purposes of Sentencing (2/12/01)

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In United States v. Gillen , 2011 U.S. Dist. LEXIS 12606 (WD PA 2/9/11) , the defendant entered a plea agreement in which he stipulated to t...
Friday, February 11, 2011

The Mass Document Dump and the Prosecutors' Brady Obligations (2/11/11)

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In United States v. Ohle , 2011 U.S. Dist. LEXIS 12581 (SD NY 2011), here , aff'd 2011 U.S. App. LEXIS 21275 (2d Cir. 2011), the defenda...

Another Sentence To Consider When Thinking of Sentencing Disparities

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DOJ Tax CES touts this sentence on its web site here . The read on the site is short, so I encourage readers to look at it. Here's the g...
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New Statute for Civil Effect of Restitution in Tax Cases (2/11/11)

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Tax crimes afficionados know that restitution is not available for a Title 26 tax crime of conviction but is available if the crime of convi...
Tuesday, February 8, 2011

IRS Announces Second Special Voluntary Dislcosure Initiative for Offshore Accounts

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The IRS announced today a special voluntary disclosure program. For now, I will just link to the announcement here . and provide only the bu...
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Can I Just Pay and Make the Investigation / Prosecution Go Away?

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Criminal tax practitioners often are asked early in the representation (and often more than once) whether, if the client under investigation...
Saturday, February 5, 2011

First Sentencing in Offshore Case that Went to Trial (2/5/11)

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Maricio Cohen Assor and Leon Cohen-Levy, previously blogged here , were sentenced yesterday. I include below links to the SD FL USAO press r...
5 comments: