Federal Tax Crimes

Jack Townsend offers this blog on Federal Tax Crimes principally for tax professionals and tax students. It is not directed to lay readers -- such as persons who are potentially subject to U.S. civil and criminal tax or related consequences. LAY READERS SHOULD READ THE PAGE IN THE RIGHT HAND COLUMN TITLE "INTENDED AUDIENCE FOR BLOG; CAUTIONARY NOTE TO LAY READERS." Thank you.

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Jack Townsend: Houston, TX, United States

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Federal Tax Crimes

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Court of Federal Claims Holds that Not Reading The Schedule B Foreign Account False Answer Justifies FBAR Willful Penalty (12/28/18)

Article on Ethics Issues in Referring Clients to Foreign Aggressive Tax Planners/Enablers (12/27/18)

Tax Court Case Shows That the IRS Burden to Prove Fraud by Clear and Convincing Evidence Is Formidable Indeed (12/17/18)

Bedrosian on Appeal; Interesting and Potentially Important Opinion on Jurisdiction in FBAR Penalty Cases (12/21/18; 1/10/19)

Articles on Potential Tax Crimes in the Trump Hush Money Payments (11/20/18)

Does the Statute of Limitations Affect the Issue of Whether a President Can be Indicted During His Presidency? (12/13/18; 12/17./18)

Tax Court Holds that an Aider and Abetter of Tax Evasion Assessed Tax for Another's Tax May Be Assessed under § 6201(a)(4) (12/13/18)

FBAR Collection Suit Against Person Convicted of Willfully Failing to File FBAR (12/11/18)

District Court Rejects Motion to Dismiss Based on Colliot and Wadhan Because Each Year Willful Penalty Less than $100,000 (12/10/18)

USAO SDNY Sentencing Memo for Michael Cohen for Tax and Other Crimes (12/9/18)

Haaretz Article On New DOJ Entity Prosecution Policies and Isreali Banks (12/5/18)

Enablers and Taxpayer Related to Panama Papers Disclosures Indicted (12/4/18)

Supreme Court Case on Double Jeopardy that Might Affect States' Ability to Prosecute Tax Crimes After Federal Jeopardy (12/3/18; 12/6/18)

New DOJ Policies for Prosecution of Entities and the Individuals Within Them Most Responsible (11/30/18)

New IRS Voluntary Disclosure Procedures and Civil Resolution Framework (11/29/18; 11/30/18)

Use or Abuse of Joint Defense Agreements: Which Is It for Manafort and Trump? (11/28/18)

Another Offshore Account Plea to One Count of Tax Perjury (11/15/18)

Defense to Evasion of Payment by Fictitious Instruments--the IRS "Monetized" and Holds the Proceeds in a Secret Fund (11/28/18)