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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,...
Saturday, January 11, 2025

Updates on Developments in IRS Penalty Administration and Voluntary Disclosure (1/11/25)

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I post here links to earlier posts on my Federal Tax Procedure Blog about the IRS’s Voluntary Disclosure Practice (“VDP”). ABA Tax Section C...
Friday, December 20, 2024

Paul Daugerdas' 15 Year Sentence is Commuted with Only Around 9 Years' Incarceration Served (12/20/24)

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I learned today that, on December 12, 2024, President Biden commuted the sentence of Paul Daugerdas who, as described in the DOJ press relea...
Thursday, December 19, 2024

District Court Revokes Bail and Orders Pretrial Incarceration in Tax Crimes Case Because of Violations of No Contact Requirement (12/19/24)

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Added at 12/21/24 9:00pm : I enclose below a ChatGPT summary of this blog. I encourage readers to take a look. Pretty good summary. We don’t...
Friday, December 13, 2024

DOJ December 2023 Publication on Tax Enforcement (12/13/24)

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This blog entry will alert readers of the following publication: Misc. Authors, Tax Enforcement , 71 DOJ J. Fed. Law & Prac., No. 4 (Dec...
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...
2 comments:
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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The opinion discussed in this blog was vacated by  United States v. Schwarzbaum , ___ F.4th ___ (11th Cir.1/23/25), CA11 here and GS here [...
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...