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Friday, November 29, 2019

D.C. Circuit Swats Down Bullshit Tax Shelter (11/29/19)

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In Endeavor Partners, LLC v. Commissioner , ___ F.3d ___ (D.C. Cir. 2019), here , the Court affirmed the Tax Court’s strike-down of yet anot...
Monday, November 25, 2019

New LB&I Campaign for Post OVDP Compliance (11/25/19)

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I previously reported that IRS LB&I included among its “campaigns” OVDP Declines-Withdrawals Campaign.  IRS LB&I "Campaigns...
Tuesday, November 19, 2019

RICO Claim Dismissed Against Bullshit Tax Shelter Promoters (11/19/19; 11/22/19)

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In Menzies v. Seyfarth Shaw LLP , __ F.3d ___ (7th Cir. 2019), here , the Court dismissed a RICO claim arising out of an alleged fraudulent ...
Sunday, November 17, 2019

Report of IRS Criminal Interest in Captive Insurance Shelters (11/17/19)

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It is reported that the IRS is looking to make criminal referrals to CI in § 831(b) captive insurance cases.  Jay Adkisson, IRS Suggests Cri...
Wednesday, November 13, 2019

Sixth Circuit Holds that Courts Cannot Enjoin IRS From Receiving or Using Alleged Confidential Info from Former Attorney (11/13/19)

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In Gaetano v. United States , 2019 U.S. App. LEXIS 33164 (6th Cir. 2019), here , the Gaetanos (husband and wife) sued the United States to e...

Negotiating Misdemeanor Plea in Lieu of Felony in Tax Crimes Cases? (11/13/19)

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In United States v. Christensen , 2019 U.S. Dist. LEXIS 193864 (D. AZ. 2019) (Magistrate Report and Recommendation), here , Gary Steven Chri...
Monday, November 11, 2019

Net Worth, Corroboration of Defendant's Statements and Corpus Delecti (11/11/19)

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One of my weekly automated searches picked up this recent case quote from United States v. Tanco-Baez , Nos. 16-1322, 16-1323, 16-1563, 2019...
Sunday, November 10, 2019

Court of Appeals for Federal Circuit Affirms CFC Norman Holding that Taxpayer is Subject to FBAR Willful Penalty (11/10/19; 11/13/19)

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In Norman v. United States , (Fed. Cir. 11/8/19), here , the Federal Circuit sustained an FBAR willful penalty, holding: 1. FBAR willfulne...
Saturday, October 26, 2019

Government Alleges Misconduct By Attorney in FBAR Related Summons Enforcement Case (10/26/19)

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I ran across an article on Law360:  NY Man's Atty Made False Statements In FBAR Row, US Says (Law360 10/21/19), here (subscription req...
Tuesday, October 22, 2019

California Attorney, a Prior Tax Offender and Embezzler, Pleads Guilty to tax Evasion (10/21/19)

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I received an email from IRS CI announcing the following plea James Roy McDaniel, 66, who pleaded guilty before United States District Jud...
Monday, October 14, 2019

Make Tax Crimes Great Again Caps for Sale (10/14/19; 6/2/22)

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I am offering for sale the "official" cap -- Make Tax Crimes Great Again (see image at right). I offer them for a per unit cost ...
Saturday, October 12, 2019

A Reminder on the Cheek Good Faith Defense -- It Usually Does Not Work (10/12/19)

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The United States Attorney for Nevada announced here the sentencing of William Waller Jr., a Las Vegas real estate broker and the owner of...
Friday, October 4, 2019

Eleventh Circuit Remands for Better Restitution Calculation (10/5/19)

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In United States v. Sheffield , ___ F.3d ___ (11th Cir. 2019), here , the Court remanded to the district court for a more precise calculatio...
Thursday, October 3, 2019

DOJ Tax New Crime-Fraud Strategy (10/3/19)

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I recommend to readers this short introduction to DOJ Tax's recent initiatives for the crime-fraud exception to the attorney-client priv...
Wednesday, October 2, 2019

N.C. Doctor Sentenced for Tax Evasion (10/2/19)

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One of the downsides of paying too much attention to Federal Tax Crimes is to see people who abuse the privileges that they have received in...

Guilty Plea for Lying on Pre-Sentencing Financial Disclosure Form (10/2/19)

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I previously reported on the guilty plea and sentencing of Casey Padula for tax and bank fraud.  See  Another Offshore Account Guilty Plea C...
Thursday, September 26, 2019

District Court Confuses Analysis in Approving Magistrate's R&R Imposing FBAR Willful Penalty (9/26/19)

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I previously reported on the Magistrate's Report and Recommendation in United States v. Rum (M.D. Fla. No. 8:17-cv-826-T-35AEP). See Ma...
Monday, September 23, 2019

§ 7202 Convictions Reversed for Improper Bad Acts Evidence (9/23/19)

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In United States v. Snyder , 2019 U.S. App. LEXIS 28326 (6th Cir. 9/19/19) (unpublished), here , Snyder fell into the not uncommon trap of u...