Updates for Prior Blog Postings (9/29/21)

Starting 5/4/20, I will use this page to link to blog posts that I have updated with subsequent information that I do not feel is important enough to warrant a new blog post.  The table below is in reverse chronological order of the postings.  In the title of this page, I will show the date of the last update.


Blog Post

Update Info


ABA Tax Section Comments on Voluntary Disclosure Practice and Streamlined Filing Compliance Procedures (9/28/21), here

Made comments to the posting


Grand Jury Indicts Alleged Offshore Willful Actor Who Should Have Entered OVDP But Attempted SFCP (9/24/21; 9/27/21), here

Added comments regarding the indictment


Judge Holmes Weighs (At Length) Against Taxpayers Involved in Complex Bullshit Tax Shelters; Fraud Penalties Approved (7/14/21; 7/15/21), here

Added to JAT Comments new paragraph # 3 discussing the § 6700 penalty

7/2/21 & 7/4/21

Preliminary Comments on the Trump Organization and CFO Indictment (7/2/21; 7/4/21), here

Added ¶¶ 10, 11 12 added further regarding statutes of limitations (¶¶ 10 and 11) and regarding DOJ Petite Policy re Dual and Successive Prosectuion (¶ 12,


Tax Court Opinion with Cryptic Comment on Excessive Restitution Based Assessments (6/24/21; 6/25/21), here

Revised to delete long quotes from article that were not consistent with copyright and, instead, provided links to the portions of the article that were deleted


Tax Court Opinion with Cryptic Comment on Excessive Restitution Based Assessments (6/24/21; 6/25/21), here

Substantially revised the commotion and added further link to other blog discussion.


Tax Court Opinion with Cryptic Comment on Excessive Restitution Based Assessments (6/24/21; 6/25/21), here

Fleshed out the background for the issue raised in the original text and pointed to a Procedurally Taxing Blog discussioni


S.G. Files Brief in Opp to Petition for Certiorari in Flynn (5/19/21; 6/17/21), here

Updated to include Flynn’s reply brief filed 6/7/21 and offer comments on a distracting footnote


Houston Tax Attorney Indicted for Conspiracy and for Aiding and Assisting (4/15/21; 4/16/21), here

Added link to Kepke indictment and a couple of comments


CA6 Rejects Taxpayers Argument for Bankruptcy Discharge Based on Exception to Discharge for Intent to Evade Tax (4/14/21; 4/15/21), here

Added link to Lavar Taylor’s discussion of Ninth Circuit application of 11 USC § 523(a)(1)(C).


CA9 Holds in Boyd that Nonwillful FBAR Civil Penalty Is Per Form Rather Than Per Account When Correct Delinquent FBAR Is Filed (3/24/21; 3/31/21)), here

Added great comments by Lavar Taylor, the Boyd’s lawyer in the case


Daugerdas Fails in Post-Conviction Hail Mary Motion (2/17/21; 12/19/21), here

Added par. 4 to discuss the Court’s holding on the Wartime Suspensions of Limitations Act (18 U.S.C. § 3287, here, “WSLA”) for the nontax crimes of conviction and advise that a separate blog will be offered with more on the WSLA issues.


Corporate Transparency Act – Beneficial Ownership of Shell Corporations Must Be Disclosed (1/8/21), here

Added JAT Comment #2 to provide article and link to article.


FinCEN Notice 2020-2 to Make Virtual Currency Foreign Accounts FBAR Reportable (12/31/20; 1/16/21), here

Added recent article name and link.


Deloitte and Tax Analysts Open Tax Analysts Library to Public Without Subscription (1/11/21; 1/12/21), here

Added some other free web research resources that I find helpful


First Criminal Cases from Abusive Syndicated Conservation Easements (12/23/20; 12/29/20), here

Made changes to the JAT Comments section designed to be a better teaching tool for the Sentencing Guidelines considerations


Individual B, the Houston Attorney in the Smith NPA, Is Unmasked (12/1/20; 12/2/20), here

Made changes (principally additions) to JAT Comments paragraphs 3 and 4 regarding some inferences and speculations


Court Re-Calculates Willful Penalties Found to Be Arbitrary (5/18/20; 8/28/20), here

Added paragraph 12 to report the Court’s entry of order altering or amending the judgment on the Government’s motion to set the penalties at lower amounts actually assessed by Treasury.


A Bit of History: Andrew Mellon and Tax Fraud (8/12/20; 8/14/20)

Added comment 1 requesting information about the Mellon criminal no-bill and civil trial


The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 8/2/28), here

Added a discussion (par. 7) discussion a practitioner’s comments.


The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 7/29/28), here

Added 3 more comments (pars. 4-6) relating to the deficiency calculation for the Tax Court


The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 7/28/28), here

Added 3 comments (pars. 1-2 relating to the claim for refund example and adding one related to analogous IRS conduct (par. 3)


Revised IRS Form 14457 for Voluntary Disclosure Preclearance (5/29/20; 7/17/20),here

Added bullet points from discussion of the Form and process from the ABA Tax Section May Civil and Criminal Tax Penalties telecast on 7/14/20.


New CTM discussion on § 7212(a) re Marinello (7/1/20; 7/12/20), here

Added the points I thought worth mentioning after review of the revised CTM


Court Re-Calculates Willful Penalties Found to Be Arbitrary (5/18/20; 5/26/20), here.

Added Comment 9 to alert readers to the Court’s holding that the FBAR willful penalty does not violate the Eighth Amendment excess fine prohibition.


Court Re-Calculates Willful Penalties Found to Be Arbitrary (5/18/20; 5/26/20), here.

Added (1) in comment 7 a trajectory of the taxpayer in conjunction with the history of the offshore account initiative and (2) comment 10 a discussion of the entry of judgment


Compassionate Release from Incarceration Based on COVID-19 Pandemic (4/20/20; 5/7/20), here

Denial of Compassionate Release for Paul Daugerdas