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Wednesday, March 27, 2019

9th Circuit Affirms Convictions for Tax Perjury, § 7206(1) (3/27/19)

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In United States v. Hardy , 2019 U.S. App. LEXIS 8336 (9th Cir. 2019) (unpublished), here and here , the Court affirmed the Hardy's co...

11th Circuit Affirms Convictions of Promoters of Insurance Premium Scam Bullshit Tax Shelter (3/27/19)

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In United States v. Donaldson , 2019 U.S. App. LEXIS 8684 (11th Cir. 2019) (unpublished), here  and here , the Tenth Circuit affirmed the di...
Thursday, March 21, 2019

TRAC Report on Sentencing Discretion and Disparity (3/21/19)

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Transactional Records Access Clearinghouse ("TRAC"), a great resource for information about the federal government (see here ), ha...
Wednesday, March 20, 2019

Eighth Circuit Affirms Tax Obstruction Conviction without Proper Marinello Jury Instructions (3/20/19)

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In United States v. Beckham , ___ F.3d ___, 2019 U.S. App. LEXIS 6964 (8th Cir. 2019), here , the Court affirmed Beckham's conviction fo...
Tuesday, March 19, 2019

Bank Hapaolim Increases Its Reserve for U.S. DOJ Tax Investigation (3/19/19)

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Israel's Bank Hapoalim Q4 net profit sinks on U.S. tax probe provision (Reuters 3/18/19), here .  Excerpt: The bank said earlier this...
Thursday, March 14, 2019

DOJ Tax and Mizrahi-Tefahot Bank Ltd. (Israel) Reach DPA (3/13/19)

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DOJ Tax announced here the DPA with Mizrahi-Tefahot Bank Ltd., (Mizrahi-Tefahot) and its subsidiaries.  I have not been able to find the un...
Wednesday, March 13, 2019

On the Manafort Sentences and Tax Crimes Sentencing (3/13/19)

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I have hesitated to write on the Manafort sentencing principally because, although Manafort was convicted of tax crimes and FBAR crime that ...
Thursday, March 7, 2019

Court Affirms Defraud Conspiracy Conviction; Rejects Lesser Included Offense Argument (3/7/19)

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In United States v. Bradley , 917 F. 3d 493 (6th Cir. 2019), CA6  here  and GS here , the court affirmed Bradley's defraud conspiracy co...

District Court Rejects Argument that Marinello Applies to Defraud / Klein Conspiracy (3/7/19)

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In United States v. Parlato , 2019 U.S. Dist. LEXIS 33035 (W.D. NY 2019), here , the Court rejected Parato's argument that the Supreme C...

District Court Approves FBAR Willful Penalties Under Post 2004 Law; Rejects Colliot and Wadhan (3/7/19)

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In United States v. Garrity , 2019 U.S. Dist. LEXIS 32404 (D. Conn. 2019), here , the Court rejected the argument that the FBAR willful pena...

Tenth Circuit Affirms Summons Enforcement Against Medical Marijuana Business Regarding Section 280E (3/7/19)

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Section 280E, here , denies a deduction for expenses of a trade or business which "consists of trafficking in controlled substances (wi...
Saturday, March 2, 2019

Taxpayers Fail to Prove Expenses of Medical Marijuana Business Deductible; Burden of Proof Does Not Violate Fifth Amendment Privilege (3/2/19)

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In Feinberg v. Commissioner , 2019 U.S. App. LEXIS 5618 (10th Cir. 2019), here , the taxpayers were shareholders in an LLC selling medical m...

Tenth Circuit Affirms Tax Crimes Convictions and Sentencing (3/2/19)

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In United States v. Stubbs (10th Cir. 2019), here , a nonprecedential decision, the Court affirmed Stubbs' convictions and sentencing ...
Wednesday, February 27, 2019

Default Judgment Entered Against Convicted Defendant Who Agreed to Penalty (2/27/19)

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In  United States v. Sarshar , 2019 U.S. Dist. LEXIS 27845 (C.D.Cal.2019), the court rendered default judgment against Masud Sarshar in the ...

11th Circuit Holds Relevant Conduct Loss for Guideline Calculation Can Be Less Than Loss Within Scope of Criminal Conspiracy (2/27/19)

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In United States v. Anor , 2019 U.S. App. LEXIS 4858 (11th Cir. 2019), here , Anor was a relatively low level employee in a tax preparation...
Thursday, February 21, 2019

Willful Blindness - Is It An Inference of Knowledge or Intent or Is It a Substitute (2/21/19)

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I am back on one of my pet peeves -- deliberate ignorance.  (Deliberate ignorance is also called willful blindness or conscious avoidance; i...

10th Circuit Reverses Tax Money Laundering Conviction For Lack of Sufficiency of Evidence (2/21/19)

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In United States v. Christy , ___ F.3d ___, 2019 U.S. App. LEXIS 4594 (10th Cir. 2019), here , the Court opens with this summary: On May ...
Wednesday, February 20, 2019

UBS Fined $4.2 Billion for Its French Foreign Account Escapades Raiding France of Taxes (2/20/19)

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Liz Alderman, French Court Fines UBS $4.2 Billion for Helping Clients Evade Taxes (NYT 2/20/19), here . Excerpts The lavish spending ca...