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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Superseding Indictment for Former Harvard Chair on Tax and FBAR Crimes (7/29/20)

The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 8/2/20)

IRS Return Information Disclosures to Other Federal or State Authorities for Information Obtained in Voluntary Disclosure Processing and other Agency Activity (7/18/20)

Second Circuit Affirms Convictions, Rejecting Marinello and Bad Acts Evidence Arguments (7/9/20)

Sixth Circuit Affirms Conviction, Upholding Relevant Conduct Tax Loss Attributable to Defendant's Conduct (7/8/20)

New CTM discussion on § 7212(a) re Marinello (7/1/20; 7/12/20)

District Court Holds FBAR Nonwillful Penalty Is Per Form Rather than Per Account (6/30/20)

U.S. Brings Summons Enforcement Suit against Del. Dept of Insurance re Micro-Captives (6/23/20)

Swiss Financial Institution Clients May Have Claims for Hidden Fees (6/12/20)

Extradited E&Y Tax Shelter Enabler Sentenced (6/9/20/ 6/10/20)

District Court Denies Gov't Summary Judgment in FBAR Collection Suit (6/4/20)

IRS Solicitation for Outside Expertise in CryptoCurrency Audits (5/31/20)

Revised IRS Form 14457 for Voluntary Disclosure Preclearance (5/29/20; 7/17/20)

District Court Rejects Defendant's Creative Claim that Alleged Overpayments of Other Taxes Precludes Criminal Liability (5/28/20)

Confusion as to Sentencing Guidelines Tax Loss and Civil Tax Loss Requires Remand and Resentencing (5/21/20)

Court Re-Calculates Willful Penalties Found to Be Arbitrary (5/18/20; 8/28/20)

Article on Renewed Focus on Criminal Tax Enforcement (5/17/20)

District Court Denies Summary Judgment on Willfulness But Finds Penalty Allocation Arbitrary and Capricious (5/15/20)