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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Good Article On Open Pleas vs. Negotiated Plea Agreements (12/15/22)

Carlos Kepke, Indicted Tax Lawyer Allegedly Enabling Large Tax Evasion Offshore Schemes, Dies Just Before Start of Criminal Trial (11/28/22)

Tax Attorneys Indicted for Fraudulent Tax Shelter and Related Conduct (11/18/22)

District Court holds in Tax Perjury (§ 7206(1)) Case That Defendant Can Introduce Evidence that IRS Failed to Pursue Civilly (11/12/22)

Supreme Court Oral Argument in Bittner Re FBAR NonWillful Penalty Per Account or Per Form (11/3/22)

Is It a Variance for the Indictment to Allege Use of Attorney Client Trust Fund for Evasion When the Proof Showed only Attorney Trust Fund? (10/18/22)

The Kepke (Brockman and Smith Lawyer Enabler) Prosecution - Developments (10/27/22)

Court Rejects No Harm (Tax Loss) No Criminal Foul for Defraud Conspiracy in Backdating to Allocate Partnership Losses to New Partners (10/27/22)

Amicus Briefs in Supreme Court Bittner Case on Nonwillful FBAR Penalty Per Form or Per Account (10/12/22)

Tax Court Soundly Rejects Taxpayers' Motion to Compel Immunization of Third Party Witnesses (10/3/22)

Supreme Court Grants Cert to Determine Whether Dual-Purpose Communications Involving Legal and Non-Legal Advice (in Tax Return Preparation Setting) is Protected by Attorney-Client Privilege (10/3/22)

Brockman Jeopardy Assessment of $1.4+ Billion Sustained (10/2/22)

Government Moves for FBAR Willful Penalty Judgment in Schwarzbaum (9/15/22)

Tax Court Sustains Accuracy-Related Penalty for Offshore Accounts, Rejecting Taxpayer's QAR, Statute of Limitations, and § 6751(b) Arguments (9/1/22)

FBAR Willful Penalty (with Collection Suit) after OVDP Drop Opt-Out (9/1/22)

Sixth Circuit Holds Harmless Error to Not Give Correct Jury Instruction on Evasion Statute of Limitations (8/31/22)

Senate Press Release and Report on Offshore Evasion Through Shell Banks Skirting FATCA (8/28/22)

More on Tax Due and Owing and Tax Deficiency (8/28/22)