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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Court Seems to Hold that Tax Willfulness Good Faith Defense Requires the Defendant to Testify (6/15/22)

Third Circuit Sustains FBAR Willful Penalty (6/7/22)

Government Suit to Enforce JDS to Offshore Promoter (5/29/22)

Brockman Found Competent to Stand Trial (5/24/22)

Unposting of Blog Entry (5/21/22)

Solicitor General Acquiesces in Bittner Petition for Cert on Issue of FBAR Nonwillful Penalty Per Form or Per Account (5/19/22)

District Court Retains Jurisdiction While Arbitrary and Capricious FBAR Willful Penalty Amount is Remanded to IRS for Recalculation (5/18/22)

First Circuit Sustains Willful Penalty Where Willfulness Found as Discovery Sanction (5/2/22)

Credit Suisse Taking Another Rap on the Knuckles (4/22/22)

TIGTA Report on IRS Effort to Enforce FATCA (4/12/22)

District Court Concludes More Likely Than Not that President Trump and John Eastman Committed the Defraud Conspiracy (4/4/22)

More Thrashing in Schwarzbaum on Effect of Eleventh Circuit's Remand to Remand to IRS on Statute of Limitations (4/1/22; 4/7/22)

Summary of Tax Crimes for Tax Procedure Class (3/31/22)

More District Court Thrashing Around on Arbitrary and Capricious Calculation of Willful FBAR Penalties (3/30/21)

District Court Rejects Claim That Supreme Court Expansion of Defraud Conspiracy Is In Error (3/24/22; 3/27/22)

District Court Rejects Summary Judgment for FBAR Civil Willful Penalty (3/12/22; 3/13/22)

Follow On Cases After Criminal Tax Convictions--Daugerdas and Larson (2/8/22)

Second Circuit Affirms Tax Court that IRS Withdrawal of Certification of Seriously Delinquent Tax Debt to Secretary of State Makes § 7435 Proceeding Moot (2/1/22)