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Monday, March 30, 2020

Bullshit Shelter Taxpayers Continuing FOIA Litigation to Identify Informants Turning Them In to IRS (3/30/20)

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FOIA requests and litigation have not been featured prominently on this blog.  For this entry, FOIA litigation is front and center, but inte...
Saturday, March 21, 2020

District Court Muddles an FBAR Willful Penalty Case (3/21/20; 3/24/20)

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I made a key revision on 3/24/20 at 4:00pm as indicated in red below to state with cites to the statute that the willful FBAR willful penalt...
Thursday, March 19, 2020

Fifth Circuit Erroneously Describes Defraud Conspiracy as Conspiracy to Commit Tax Fraud (3/19/20)

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In United States v. Scully , ___ F.3d ___ (5th Cir. 3/4/20), here , the Fifth Circuit affirmed Scully’s convictin for “(1) conspiracy to def...
Wednesday, March 18, 2020

Swiss Bank Account Records as Business Records for Hearsay Exception (3/18/20)

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In a designated order, Tax Court Judge Lauber rejected taxpayer objections to the introduction of records obtained by the IRS pursuant to th...
Monday, March 16, 2020

DOJ Tax Announces Convictions in Massive Biodiesel Tax Fraud (3/16/20)

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This DOJ Tax announcement is noteworthy even though it does not involve one of the Title 26 crimes or a conspiracy to commit a Title 26 offe...
Monday, March 9, 2020

Another Plea Related to Offshore Accounts (3/9/20)

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DOJ Tax issued this press release:  Alabama Salesman Pleads Guilty to Tax Evasion: Defendant Used Offshore Insurance Wrapper Accounts to Con...
Sunday, March 1, 2020

U.S. Accountant Enabler Connected with Panama Papers Pleads Guilty (3/1/20)

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DOJ has this press release: U.S. Accountant Pleads Guilty in Panama Papers Investigation (2/28/20), here .  Key excerpts are: A Massachu...
Friday, February 28, 2020

District Court Sustains FBAR Civil Willful Penalty (2/28/20)

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In United States v. Ott (E.D. Mich. Dkt. 2:18-cv-12174 2/26/20), here , the district court sustained the IRS assertion of willful FBAR pena...
Wednesday, February 26, 2020

Disqus Comment Problems - Hopefully Resolved (2/21/20)

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I just realized late last week that there were some disqus comment problems that have apparently been going on for at least a couple of mont...
Wednesday, February 19, 2020

Two Articles on Swiss Banks (2/19/20)

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This is just a miscellaneous post on Swiss Banks to report two recent articles on two different topics. Samuel Gerber, U.S. Tax Dispute:...
Wednesday, February 12, 2020

D.C. Circuit Rejects Claim that Admissions were Coerced (2/12/2020)

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In United States v. Cooper , ___ F.3d ___, 2020 U.S. App. LEXIS 4153 (D.C. Cir. 2020), here , two defendants, along with another (described ...

Ninth Circuit Botches Evasion of Assessment Statute of Limitations (2/12/20)

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In United States v. Galloway , 2020 U.S. App. LEXIS 3976 (9th Cir. 2020) (unpublished), here , Galloway was convicted of four counts of tax...

Eighth Circuit Affirms Tax Preparer Conviction, Rejecting Argument for Search Warrant Suppression (2/12/20)

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In United States v. Keleta , ___ F.3d ___, 2020 U.S. App. LEXIS 3566 (8th Cir. 2020), here , the court sustained Keleta’s conviction for “co...
Monday, February 10, 2020

Convicted Tax Protestor's Bid for Competency Hearing Fails on Appeal (2/10/20)

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In United States v. DiMartino (2d Cir. No. 18-2053-cr 2/4/19), here , the Court of Appeals affirmed a tax protestor conviction described as...

U.S. Tax Attorney Denied Habeas Corpus in Extradition Proceeding Based on Netherlands Criminal Tax Conviction (2/10/20)

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In Valentino v. United States Marshal (S.D. Tex. Civ. Action 4:20-CV-304 order dated 1/30/20), here , the court denied Valentino’s request ...
Thursday, January 30, 2020

Follow Up on the Biggest Tax Heist Ever (1/30/20)

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I wrote previously about an alleged scheme to steal revenue from various European countries based on claims for refund from so-called “cum-e...
Friday, January 24, 2020

Excellent Decision for D.C. District Court on Brady Disclosures in Mass Document Dumps (1/24/20)

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Some of the more high profile tax crimes cases, like the broader category of white collar crime, have large document sets that the Governmen...
Thursday, January 23, 2020

NYT Article on Perhaps Biggest Tax Heist Ever (1/24/20)

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The NYT has this article:  David Segal, It May Be the Biggest Tax Heist Ever. And Europe Wants Justice  (NYT 1/23/20), here .  I haven't...