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Thursday, March 29, 2018

Article On UH Tax Fraud and Money Laundering Student (3/29/18)

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Today, I write to offer an article from WAPO on a former student, Drew Willey.  His Clients Weren’t Complaining. But the Judge Said This Law...

Lawyers as Enablers in Money Laundering (3/29/18)

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Amol Mehra, My law degree wasn’t meant for money laundering. But boy, it would make it easy (WAPO 3/29/18), here . I didn’t pursue a law ...
Tuesday, March 27, 2018

Statistics and Extrapolations on Tax Cheating in the US (3/27/18)

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This is an interesting article with some data and some extrapolations from the data. A high level overview of who cheats (at least certain s...
Saturday, March 24, 2018

What Are the Implications for Marinello on the Defraud / Klein Conspiracy? (3/24/18)

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I have recently written on the Supreme Court's opinion in Marinello v. United States , ___ U.S. ___, ___ S.Ct. ___ 2018 U.S. LEXIS 1914...
Wednesday, March 21, 2018

Supreme Court Holds that Omnibus Clause of the Tax Obstruction Crime (§ 7212(a)) Requires Awareness of Pending Tax-Related Proceeding (3/21/18; 3/22/18)

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Today, the Supreme Court held in Marinello v. United States , 584 U.S. 1 (2018), here , that "To convict a defendant under the Omnibus...

FBAR Civil Penalty Items (3/21/18)

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Items of interest to FBAR fans: First, FinCEN has updated the inflation adjustment for the FBAR civil penalties stated in $ amounts.   See...

Second Circuit Discusses Conscious Avoidance (Willful Bllindness) (3/21/18)

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In United States v. Dambelly , 2018 U.S. App. LEXIS 6382 (2d Cir. 2018), unpublished, here , the Court had some interesting language regardi...
Tuesday, March 20, 2018

Court of Appeals Affirms Exclusion of Amended Returns and Payments after Start of Criminal Investigation (3/20/18)

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In United States v. Evdokimow , 726 Fed. Appx. 889, 2018 U.S. App. LEXIS 6564 (3rd Cir. 2018) (nonprecedential), CA3  here  & GS here , ...

Two Opinions on Joinder of Tax Charges and NonTax Charges (3/20/18)

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I generally do not write about criminal cases where the gravamen of the case is a nontax crime but with a tax crime charge which, while an ...

Ninth Circuit Rejects Bank Argument Against FDIC Cease and Desist Order from Failure to File SAR (3/20/18)

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I have previously written on the Bank Secrecy Act requirement that financial institutions file Suspicious Activity Reports ("SARs...
Tuesday, March 13, 2018

IRS to Ramp Down and Then End OVDP on 9/28/18, But the Streamlined Procedures for Offshore Assets Will Continue for Now (3/13/18)

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The IRS has announced that it will "begin to ramp down [OVDP] * * * and close the program on Sept. 28, 2018."  IR-2018-52, here  ...
Saturday, March 10, 2018

Seventh Circuit Holds that Attorney Advising Client to Plead Guilty Without Discovery from the Government Was Strategic Decision Rather than Ineffective Representation (3/10/18)

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In United States v. Jansen , 2018 U.S. App. LEXIS 5755 (7th Cir. 3/7/l8), here , Jansen pled to "to one count of wire fraud and one cou...
Tuesday, February 27, 2018

IRS OVDP Declines-Withdrawals Campaign (2/27/18)

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Late last year, IRS LB&I announced here certain compliance "campaigns" for examinations.  Among the campaigns is the followin...
Monday, February 26, 2018

Coinbase Will Comply with JDS on Approximately 13,000 Customers for Bitcoin Transactions (2/26/18)

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I have reported before about the IRS John Doe Summons issued to Coinbase, a digital currency exchange.  See Court Orders Enforcement of John...
Saturday, February 24, 2018

Willful Blindness -- Does the Concept Expand the Statutory Element of the Crime of Knowledge? (2/24/18)

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In United States v. Carbins , 2018 U.S. App. LEXIS 3585 (5th Cir. 2018), here , the defendant "was convicted of one count of conspiracy...

Taxpayers with Failed Bullshit Tax Shelters Use FOIA to Try to Get Whistleblower, if any, Information (2/24/18).

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In Montgomery v. IRS , 2018 U.S. Dist. LEXIS 26313 (D. D.C. 2/20/18), here , taxpayers were caught using partnerships to claim large tax ben...

Congress Amends Tax Whistleblower Section, § 7623, to Clarify Broad Reading of the Award Base (2/24/18)

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Earlier this month, Congress amended the mandatory minimum tax Whistleblower award program to make clear that proceeds for purposes of the a...
Sunday, February 18, 2018

Recent Articles of Interest to Tax Crimes Fans (2/18/18)

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Fran Obeid, Passport Revocation Begins for 'Seriously Delinquent Tax Debt ,' 259 NYLJ No. 19 1/29/18), here . Jeremy Temkin, The ...