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Thursday, March 29, 2012

New Policy - Inappropriate Comments Will Not Be Approved (3/29/12)

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I have today instituted a new policy.  The new policy (accessible in the Rules for Comments in the upper right column) is: 4.  Beginning 3...
12 comments:
Tuesday, March 27, 2012

IRS Statistics - General and Criminal Specific (3/27/12)

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The IRS has published a new data book, the 2011 Data Book, here , with all sorts of interesting statistics relating to its revenue enforceme...
11 comments:
Saturday, March 24, 2012

Plea Bargains Generally and in Tax Cases; Moneyball (3/24/12)

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In two cases, the Supreme Court has recognized the central role of plea bargaining in the criminal system and held the the right to effectiv...
7 comments:
Wednesday, March 21, 2012

Form 8938 and Real Estate (And Other Foreign Assets) (3/21/12)

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An issue that has been discussed via comments to various blogs is whether foreign real estate must be reported on Form 8938.  The Form 8938...
23 comments:
Monday, March 19, 2012

Recent Discussion of Required Records and Other Foreign Bank Issues (3/19/12)

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With the permission of Tax Analysts, I post Marie Sapirie's article titled International Tax Enforcement 3.0 , 2012 TNT 48-3 (3/12/12), ...
4 comments:
Friday, March 16, 2012

Jack Is Out of Range Until Monday (3/16/12)

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I will have limited access to the internet until Monday.  Hence, the most I can do is to approve comments once or twice in the interim when ...
2 comments:
Wednesday, March 14, 2012

Yet Another Swiss Enabler Indicted (3/14/12)

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The indictment is of Hans Thomann.  The indictment is  here .  The key allegations in the indictment are: Enabler Defendant :  Hans Thoman...
2 comments:

Another Swiss Enabler Indicted (3/14/12)

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The indictment is of Josef Beck.  The indictment is here .  The key allegations in the indictment are: Enabler Defendant :  Josef Beck E...
Tuesday, March 13, 2012

Ninth Circuit Speaks on FOIA, but Ducks Fugitive Disentitlement (3/13/12)

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A common parry in a tax criminal investigation or prosecution is to file a FOIA request with the IRS.  The IRS / DOJ thrust is to resist.  I...
Thursday, March 8, 2012

Tax Practitioner Self-help Defense Fails (3/8/12)

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Criminal defense attorneys are always thinking about ways to win their cases.  Defendants also have a keen interest in winning. One of the...
Wednesday, March 7, 2012

Rambo Judge Grants Mercy to Convicted Foreign Account Holder (3/7/12)

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In United States v. Purpura , 2012 U.S. Dist. LEXIS 28748 (MD PA 2012), Judge Sylvia H. Rambo granted the convicted defendant's motion t...
8 comments:

Adventures with the New Form 8938 / Section 6038D (3/7/12)

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This blog post will offer a place for readers to share their experiences and observations for the Form 8938, Statement of Specified Foreign ...
65 comments:
Tuesday, March 6, 2012

Reasonable Doubt and Mickey Mouse (3/6/12)

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Everyone knows that, in our system, to convict of a crime requires that the fact finder determines guilt beyond a reasonable doubt.  I have ...

Concerns and Strategies in Parallel Investigations (3/6/12)

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One of the risks in eggshell civil audits -- where risk of criminal prosecution is material -- is the possibility of parallel investigations...
3 comments:
Monday, March 5, 2012

TIGTA Report on IRS Undercover Operations (3/5/12)

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In a report with many redactions, TIGTA has recently reviewed CI's undercover operations and made recommendations.  See TIGTA report tit...
Friday, March 2, 2012

"Opting Out" #2 (3/2/12)

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I posted an earlier blog, "Opting Out" of OVDI and OVDP; What is Really Happening? (12/12/11), here .  Apparently the number of c...
275 comments:
Tuesday, February 28, 2012

Whistleblower Cases and the Criminal Process (2/28/12)

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Readers are at least generally familiar with the whistleblower provisions in the Code.  See Section 7263, here .  I have written on them bef...
21 comments:
Saturday, February 25, 2012

Fifth Amendment Act of Production Privilege and Encrypted Data Files (2/25/12)

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In In re: Grand Jury Subpoena Duces Tecum Dated March 25, 2011 , 670 F.3d 1335 (11th Cir. 2012), here , the Eleventh Circuit decided an impo...
1 comment: