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Thursday, September 12, 2019

New IRS Relief Program for Expatriates Renouncing U.S. Citizenship (9/12/19)

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The IRS recently announced a relief program for persons renouncing U.S. citizenship with respect to their tax compliance, including Section ...
Sunday, September 8, 2019

Confusion Regarding the Cheek Willfully Element of Specific Intent to Violate a Known Legal Duty (9/8/19)

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In United States v. Severino , 2019 U.S. App. LEXIS 26560 (11th Cir. 2019) (unpublished), here , the Eleventh Circuit affirmed Severino'...
Friday, September 6, 2019

Houston Attorney Convicted of Klein Conspiracy and Tax Evasion (9/6/19)

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DOJ Tax announced here that Jack Stephen Pursley, also known as Steve Pursley, was convicted of one count of defraud conspiracy, 18 USC § 3...
Wednesday, August 28, 2019

Court Rejects Government Summary Judgment Motion in FBAR Willful Penalty Collection Suit (8/28/19)

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In United States v. Schwarzbaum (S.D. Fla. No. 18-cv-81147), Order on Motion for Summary Judgment dated 8/23/19, here , the Court denied su...

Magistrate Recommends Sustaining Imposition of FBAR Willful Penalty (8/28/19)

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In United States v. Rum (M.D. Fla. No. 8:17-cv-826-T-35AEP), Magistrate Report and Recommendation dated 8/2/19, here , the Court granted th...
Tuesday, August 27, 2019

FBAR Collection Suit Settled Before Jury Verdict Announced (8/27/19)

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I previously reported on pretrial skirmishing in the Government's FBAR collection suit in United States v. Dadurian (S.D. Fla. 9:18-cv-...
Monday, August 26, 2019

Taxpayer Charged with False SFCP NonWillful Certification (8/26/19)

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DOJ Tax issued a press release titled "Former CPA Indicted for Failing to Report Foreign Bank Accounts and Filing False Documents with ...
Wednesday, August 21, 2019

Houston Attorney and Others Charged with Tax Crimes (8/21/19)

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The USAO for SD Texas announced issued a press release titled "Houston Personal Injury Attorneys and Case Runners Indicted," here...
Tuesday, August 20, 2019

FBAR Collection Suit for over $105 Million (8/20/19)

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A fellow practitioner alerted me to the FBAR collection suit in United States v. Burga (N.D. Cal. No. 19-cv-03246.)  The Court Listener doc...
Friday, August 16, 2019

Court Denies Motion for Partial Summary Judgment on FBAR Willful Penalties (8/16/19)

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A colleague alerted me to a Tax Notes article, titled Practitioners Balk at Potential DOJ Willful FBAR Argument (Tax Notes 8/16/19).  The T...

11th Circuit Pattern Jury Instruction Builder (8/16/19; 8/18/19)

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While reviewing some docket entries in an FBAR case in Florida, I found a docket entry referring to the Eleventh Circuit Pattern Jury Instru...
Wednesday, August 14, 2019

Court Grants Government Partial Summary Judgment on FBAR NonWillful Penalty (8/14/19)

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In United States v. Ott , 2019 U.S. Dist. LEXIS 132013 (E.D. Mich. 2019), here , the court granted the Government's motion for partial s...
Monday, August 12, 2019

2019 Federal Tax Procedure Book Editions Available (8/12/19)

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The 2019 editions of the Tax Procedure Book (Student Edition and Practitioner Edition) are available for download on SSRN as of 8/12/18.  Th...
Tuesday, August 6, 2019

Swiss Category 1 Bank Enters NPA (8/6/19)

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On August 5, 2019, DOJ Tax announced here another nonprosecution agreement (NPA) with a Category 1 Swiss Bank, LLB Verwaltung (Switzerland)...
Saturday, August 3, 2019

Restitution Based Assessment--Some Issues of Interest (8/3/19; 8/7/19)

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Readers of this blog will likely be interested in a recent post on Procedurally Taxing Blog:  Keith Fogg, Interest and Penalties on Restitut...
Tuesday, July 30, 2019

CDP Proceeding Moot Because Restitution Based Assessment and NFTL Withdrawn (7/30/19)

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In  Catlett v. Commissioner , T.C. Memo. 2019-86,  here , Catlett, a return preparer, was convicted of a defraud/Klein conspiracy (27 USC § ...

New IRS LB&I Compliance Campaigns of Interest (7/30/19)

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IRS LB&I has announced six new compliance campaigns, here . 1.  The new campaign particularly relevant for readers of this blog is: ...
Friday, July 26, 2019

IRS Sending Letters to Taxpayers with Potential Taxable Virtual Currency Transactions (7/26/19)

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In IR-2019-132, here , the IRS announced that it is "sending letters to taxpayers with virtual currency transactions that potentially f...