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.

Blog Host

Jack Townsend: Houston, TX, United States

View my complete profile

Federal Tax Crimes

Pages

Court of Appeals Finds No Harm Attorney's Failure to Assure Client Understood Relevant Conduct for Sentencing Loss Calculations (10/29/30)

Fourth Circuit Affirms District Court Decision in Tax Crimes Case to Limit Taxpayer's Reading Excerpts From Book on Cheek Willfulness Issue (10/24/20)

Corporate Taxpayer (AIG) "Settles" Tax Shelter Litigation Admitting Tax Shelters Were Shams (10/24/20)

Private Equity Guru Smith Got a Hell of a Deal (10/23/20)

Fourth Circuit Holds Taxpayer Liable for Willful FBAR Penalty (10/21/20; 11/3/20)

One Big Fish Indicted and Lesser Big Fish Achieves NPA for Cooperation (10/16/20)

District Court Grants Summary Judgment for Government on § 7431 Wrongful Disclosure Claims to Third Party Recordkeepers but Not Other Third Party Summonses (10/13/20)

New IRM provision on Offers in Compromise Including FBAR Penalties (10/8/20)

Second Circuit Affirms Conviction of Lawyer Offshore Account Enabler (10/4/20)

ICIJ Investigations In the News - Panama Papers and Suspicious Activity Reports (9/22/20; 9/25/20)

District Court Grants Government Summary Judgment on FBAR Civil Willful Penalty (9/19/20)

District Court Holds Failure to Properly Report Foreign Accounts on a Fifth Amendment FBAR Is Subject to FBAR Willful Penalty (9/18/20)

Updated CTM Chapter on Tax Related Conspiracies (9/17/20)

Second Circuit Applies the Foregone Conclusion Doctrine to Overcome the Fifth Amendment's Act of Production Doctrine (9/15/20)

IRS Continues Efforts to Crack Cryptocurrency (9/15/20)

Tax Travails of the Rich (Perhaps Famous) Enablers of the Rich (Perhaps Famous) (9/8/20)

District Court Sustains FBAR Willful Penalty But Rejects Fraudulent Failure to File Penalty for Income Tax (9/1/20)

Article on U.S. as World's Banking Policeman (8/29/20)