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Friday, October 17, 2025

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

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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 off...
Thursday, October 16, 2025

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

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Yesterday’s Wall Street Journal has an article about the Trump Administration’s alleged plan to weaponize IRS Criminal Investigation (“CI”)....
Wednesday, October 15, 2025

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

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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 t...
2 comments:
Thursday, September 4, 2025

10th Circuit Reverses on Defraud/Klein conspiracy instruction and Advice of Counsel Instruction, with Reminder on Limitations of Pattern Jury Instructions (9/4/25; 9/7/25)

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See discussion added at end on 9/5/25 @ 11:30 am. In United States v. Kearney , ___ F.4th ___ (10th Cir. 9/2/25), CA10 here and GS here [to...
Monday, August 18, 2025

Third Circuit Holds Tax Taxpayer Fraud is not Required for 6501(c)(1) Unlimited Statute of Limitations, Creating Conflict (8/18/25; 10/22/25)

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Added 10/22/25 @ 3:40pm: On October 17, 2025, the Third Circuit denied rehearing and rehearing en banc and issued a revised opinion in  Murr...
Wednesday, August 13, 2025

Court of Appeals Reverses on Statute of Limitations Grounds for Failure Foreign Evidence Tolling Under 18 USC § 3292(a)(1) and For Resentencing (8/13/25)

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In United States v. Gyetvay , 149 F.4th 1213 (11th Cir. 2025), 11th Cir.  here  amd GS here . the Court reversed Gyetvay’s convictions in ...
Thursday, July 3, 2025

Free CourtListener Docket Sheet and Documents for Major Tax Crimes Case (Also Major White Collar Crimes Case) (7/3/25)

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I write to inform principally students and young lawyers of a case with documents that can educate in both tax crimes and white collar crime...
Monday, June 30, 2025

Update on IRS Form 11457 for Voluntary Disclosure in IRS VDP (6/30/25)

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The National Taxpayer Advocate announced that, at her urging, the IRS has agreed: 1. to eliminate the Part II (complete upon acceptance in...
Sunday, June 8, 2025

AG Bondi and President Trump Violate Precepts of Criminal Justice that DOJ Tax Knows and Gets Right (6/8/25)

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 I write today on a basic premise of the criminal justice system that Trump and his minions have misrepresented in a malevolent way. I contr...
Sunday, April 27, 2025

Conflicting Statutes of Limitations for Regular Tax Assessments and Restitution-Based Assessments (4/27/25)

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In United States v. Brown (W.D. WA Case No. 24-cv-05021 Dkt. No. 38 Order dated 4/21/25), GS here and CL here , the Court upheld the vali...
1 comment:
Thursday, March 27, 2025

Can Misleading but True Statements Be Prosecuted as Criminally False Statements Under 18 USC 1001(a)(2)? (3/27/25; 3/29/25)

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In Thompson v. United States , ___ U.S. ___, ___ S.Ct. ___ (3/21/25), SC here and GS here , the Court held that the criminal conduct descri...

Sixth Circuit Holds that Forfeited Deferred Compensation Account is Not Taxable to Defendant (3/27/25)

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In Hubbard v. Commissioner , ___ F.4th ___ (6th Cir. 3/19/25), CA6 here and GS here , the Court held that the Government’s judicial forfeit...
Saturday, February 1, 2025

9th Circuit Holds that Law Firm Asserting a Fisher Privilege for Client Documents it Possesses that Are Potentially Subject to Fifth Amendment Privilege in Client's Hands Need Not Produce a Privilege Log (2/1/25; 3/31/25)

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In In re Grand Jury Investigation, dated July 21, 2023 , 127 F.4th 139 (9th Cir. 1/28/25), CA9 here and GS here , the grand jury subpoenaed...
Friday, January 24, 2025

Schwarzbaum Redux – 11th Circuit Issues New Opinion to Correct Statement of FBAR Willfulness Civil Penalty Standard (1/23/25)

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In United States v. Schwarzbaum , ___ F.4th ___ (11th Cir. 1/23/25), CA11 here and GS here [to come], the 11 th Circuit revisited the long...
Wednesday, January 22, 2025

Use of AI, Including Large Language Models (LLMs), in Tax Court Brief Writing (And Really Other Legal Analysis) (1/22/25)

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I erroneously posted on the Federal Tax Crimes Blog a post that I should have posted on the Federal Tax Procedure Blog. I have deleted the c...
Sunday, January 19, 2025

New Information for Tax Conspiracy and Related Credit Suisse (through Successor UBS) Initiatives Re Violation of 2014 Plea Agreement (1/19/25)

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In United States v. Rosenberg (S.D. FL No. 1:25-cr-20005, CL Dkt. Sheet here ), the Government filed an Information with Trial Attorney Cer...

Two Recent Tax Crimes Cases Involving Bitcoin (1/19/25; 2/9/25)

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See the additional items below added on 2/9/25. In my immediately preceding post (2 days ago) on the indictment of Tom Goldstein, I mentione...
Friday, January 17, 2025

Tom Goldstein--SCOTUSblog founder, Prominent Supreme Court Advocate, and High-Stakes Gambler--Indicted for Tax and Related Crimes and False Statements to Mortgage Lenders (1/17/25; 1/19/25)

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Yesterday's big news in tax crimes was the indictment of Tom Goldstein, the co-founder of SCOTUSblog, a big-time Supreme Court advocate,...