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Wednesday, November 13, 2024

Thoughts on IRS Web Page titled "How criminal investigations are initiated" (11/13/24)

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The IRS has a web page titled “How criminal investigations are initiated, here ” (last reviewed or updated 8/20/24 and visited 11/13/24). It...
Wednesday, November 6, 2024

Third Circuit Denies Post-Loper Bright Petition for Rehearing in Case Applying Auer/Kisor Deference (11/6/24)

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In United States v. Chandler , 104 F.4th 445 (3rd Cir. 6/11/24), CA3 here and GS here , the Court sustained a sentence based in part on the...
Wednesday, October 2, 2024

Excellent Article on IRS CI Special Agent and Cryptocurrency (10/2/24)

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I post today on an excellent article—Geraldine Brooks, The Cyber Sleuth (WAPO 10/1/24), here . This is one article in a WAPO series on “Who...
Thursday, September 26, 2024

Comments Please (9/26/24)

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I have eliminated the past comment tool (Disqus) which proved to be so daunting to readers of the blog who tried to make comments. I have re...
Wednesday, September 4, 2024

11th Circuit on Third Consideration Seals FBAR Willful Penalty Except for Relatively Small Amount Held Excessive Fine under 8th Amendment (9/4/24)

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In   United States v. Schwarzbaum , 114 F.4th 1319 (11th Cir. 2024), 11Cir   here   and GS here [to come], the Court: (1)  (a) held the FBAR...
Friday, August 30, 2024

Fifth Circuit Holds Criminal Statute of Limitations is Not Suspended for Equitable Tolling on Government's Alleged Excuses (8/20/24)

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In United States v. Plezia , 115 F.4th 379 (5th Cir. 2024), CA5 here and GS here , the Court states the facts relevant to this blog as foll...
Wednesday, August 28, 2024

Trump Superseding Indictment: More on the Defraud / Klein Conspiracy (8/28/24)

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The D.C. grand jury approved a superseding indictment against former President Trump (“Trump”). The superseding indictment is on CourtListen...
Sunday, August 25, 2024

More on United States v. Boler (8/25/24)

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Yesterday, I wrote a blog entry on  United States v. Boler , 115 F.4th 316 (4th Cir. 2024).  Fourth Circuit Applies Auer/Kisor Deference to ...
Saturday, August 24, 2024

Fourth Circuit Applies Auer/Kisor Deference to Include in Guidelines "Loss" the Commentary Inclusion of "Intended Loss" (8/24/24)

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 In  United States v. Boler , 115 F.4th 316 (4th Cir. 2024), CA4  here  and GS here [to come], the Court held that the term loss included th...
Saturday, August 10, 2024

Taxpayer Liable for Willful FBAR Penalties Despite Alleged ADHD, Stress, Depression, and Stage 3 Prostrate Cancer (8/10/24)

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In United States v. Rund (E.D. Va. No. 1:23-cv-00549 Memo Opinion & Order 8/6/24), CL here  and GS here , the Court granted the Governm...
Wednesday, August 7, 2024

Sentencing Guidelines under the Loper Bright Non-Deference Regime (8/7/24; 10/15/24)

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Three leading authorities on federal sentencing have co-authored an article that might be of interest to those interested in the confluence ...
Saturday, August 3, 2024

Is It Too Much to Ask that the Defraud Conspiracy Crime Require Fraud? (8/3/24; 8/6/24)

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In United States v. Lingat , (S.D. N.Y. No. 1:21-cr-00573 Dkt # 191 Opinion & Order 7/30/24), CL here & GS here [to come], the cour...
Sunday, July 28, 2024

Fifth Circuit Reversal of Count of Conviction Based on Statute of Limitations May Permit the Reversed Count Conduct as Relevant Conduct for Affirmed Count (7/28/24)

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In United States v. Boswell , 109 F.4th 36 (5th Cir. 2024), CA5 here and GS here , the Court reversed Boswell’s conviction for bankruptcy-f...
Friday, July 26, 2024

Federal Tax Procedure Book 2024 Editions on SSRN (7/26/24)

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The 2024 versions of the Federal Tax Procedure Book are now posted on SSRN. SSRN still has to approve them, but those interested can view or...
Saturday, June 8, 2024

Fourth Circuit Rejects Defendant's Collateral Attacks on Tax Perjury and Obstruction Convictions (6/8/24)

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In United States v. Sutherland , 103 F.4th 200 (4th Cir. 2024), CA4 here and GS here , the Court rejects the criminal defendant’s collatera...
Thursday, June 6, 2024

Sentencing Guidelines Amendment Eliminates Acquitted Conduct from Sentencing Calculations (6/6/24; 6/11/24)

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Effective 11/1/24, the U.S. Sentencing Commission has eliminated acquitted conduct as relevant conduct under §1B1.3 to enhance sentencing ca...
Wednesday, June 5, 2024

On Unanimity - the Trump NY False Documents Conviction and Federal Conspiracy Law (6/5/24)

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I will post at least this blog dealing with conceptual overlaps from the Trump trial and conviction in the New York Supreme Court (trial lev...
Saturday, May 25, 2024

Federal Tax Crimes Blog Total Pageviews Hit 10 Million + and Thoughts on Comments to Blogs (5/25/24)

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I just noticed in the innards of this Federal Tax Crimes Blog that the blog has had over 10 million pageviews. I went into the design featur...