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Friday, October 17, 2025

Interest in DOJ Tax Reunion/Wake for DOJ Tax Alumni (10/17/25)

I am trying to assess interest among DOJ Tax Alumni for a Reunion/Wake for the Tax Division. Since some DOJ Tax Alumni read this blog, I offer this link to the blog post on the DOJ Tax Alumni Blog I maintain: Fillable On-Line Form to Assess Interest in DOJ Tax Alumni Reunion/Wake (10/7/25), here.

Thursday, October 16, 2025

WSJ Article Reporting Possible Political Changes to IRS CI (10/16/25)

Yesterday’s Wall Street Journal has an article about the Trump Administration’s alleged plan to weaponize IRS Criminal Investigation (“CI”). Brian Schwartz, Richard Rubin, and  Joel Schectman, Trump Team Plans IRS Overhaul to Enable Pursuit of Left-Leaning Groups (WSJ 10/15/25), here [which requires a subscription to read].

The article reports that Trump Administration is preparing to make “sweeping changes” at the IRS by installing “allies of President Trump” at CI “to exert firmer control over the unit and weaken the involvement of IRS lawyers in criminal investigations.” The changes reportedly are “being driven by Gary Shapley, an adviser to Treasury Secretary Scott Bessent.”

The article reports on efforts to have the IRS investigate and revoke tax-exempt status for organizations, such as Harvard University, that do not bend the knee to Trump.

As respects CI, the article reports.

Shapley and those close to him are also proposing changes to the rules on how IRS criminal probes are conducted, according to people familiar with the matter. Attorneys from the IRS chief counsel’s office typically work with IRS-CI agents as they move through investigations, particularly for steps such as search warrants and bringing a case to the Justice Department for potential prosecutions. The Internal Revenue Manual, the agency’s procedure handbook, spells out the involvement of chief-counsel lawyers and the CI chief in criminal cases. It includes extra steps for sensitive cases, such as those involving federal elected officials and tax-exempt groups.

Shapley wants to change the manual so that the chief-counsel lawyers have less of a role, these people explained. 

Some senior IRS criminal tax attorneys are already voicing concern about the methods of investigators while Trump encourages his administration to target donors and nonprofit groups, according to people familiar with the matter. Some of the criminal tax attorneys have privately argued against moving ahead with at least one case, with the argument it is vindictive prosecution and seems politically motivated.

Shapley has previously complained about the IRS criminal-tax attorneys’ work with IRS-CI agents. Criminal-tax counsel “is not a respected organization within IRS-CI,” Shapley said in a 2023 congressional hearing about the Hunter Biden probe.

Wednesday, October 15, 2025

A Sad Event for the Country’s Criminal Tax Enforcement System (10/15/25)

I today write on what to me is a very sad story for our country. Roger Ver, a crypto mogul and tax evader (by his admission in the story I tell here), just bought his way out of charged tax crimes by the amounts (tax, penalties, and interest) he already owed the Government for the charged years. (There is no indication that he will pay anything for uncharged years for which the civil statute of limitations would be open if civil fraud was involved (which he did not admit under the plea agreement), nor is there any agreement that he will be required to cooperate in the determination and payment of tax liability for any other years). In other words, he bought his way out of a criminal indictment and prosecution by paying what he admitted he owed. Worse, there is more to the story as I tell below.

The key documents are

  • The plea agreement, here.
  • The DOJ Press Release, here, which says in part:

“We are pleased that Mr. Ver has taken responsibility for his past misconduct and satisfied his obligations to the American public. This resolution sends a clear message: whether you deal in dollars or digital assets, you must file accurate tax returns and pay what you owe,” said Associate Deputy Attorney General Ketan D. Bhirud. 
“Mr. Ver is accepting responsibility for his actions and has agreed to pay a substantial penalty,” said Acting United States Attorney Bill Essayli of the Central District of California. “Every person, whether you’re a millionaire or not, is required by law to pay taxes and we will not hesitate to hold anyone accountable.” 
“Today’s resolution demonstrates that there are consequences for those who intentionally conceal their assets and evade their tax obligations,” said Kareem Carter, Executive Special Agent in Charge. “No matter how sophisticated the technology or the asset, IRS-CI will continue to follow the money, ensure compliance, and protect the integrity of our tax system.”

  • The NYT article here that offers some key background including the following key paragraphs:

The case is poised to become the latest example of how the Trump administration has systematically dismantled a yearslong government crackdown on the crypto industry, a sector rife with fraud, scams and theft. 

Like other beneficiaries of the rollback, Mr. Ver sought to curry favor with President Trump by linking his case to the president’s grievances about the weaponization of the justice system.

This year, Mr. Ver paid $600,000 to Roger Stone, a longtime associate of Mr. Trump, to try to abolish the tax provisions at the heart of the case. And the crypto investor hired David Schoen, a lawyer who represented Mr. Trump during his second impeachment trial. Lobbying filings show that Mr. Ver also hired Christopher M. Kise, a lawyer who defended Mr. Trump against various criminal and civil charges, as well as the lobbying firm run by Brian Ballard, a major Trump fund-raiser.