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Wednesday, June 30, 2010

The Relevance of the Skilling Case to Tax Obstruction Crimes (6/30/10)

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A reader responded to my blog with the synopsis of the Skilling case (see here ) by stating that Skilling decision was not appropriate to a...
Thursday, June 24, 2010

Supreme Court Limits Scope of Honest Services Fraud (6/24/10)

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The Supreme Court has handed down decisions in the Jeff Skilling and Conrad Black honest-services fraud cases  ( Skilling v. United States ,...
2 comments:
Monday, June 14, 2010

Sentencing Commission Survey of Judges on Sentencing Issues

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The Sentencing Commission issued a report titled: Results of Survey of United States District Judges January 2010 through March 2010 (June 2...
Saturday, June 12, 2010

Court of Federal Appeals Trashes Son-of-Boss Shelter (6/12/10)

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The Court of Appeals for the Federal Circuit called taxpayer foul in yet another Son-of-Boss tax shelter, this time another J&G / Dauger...
Tuesday, June 1, 2010

Holder Memo on DOJ Policy on Charging and Sentencing

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AG Holder issued a memo on charging and sentencing dated May 19, 2010. The memo is here . The memo is full of glittering generalities about...
Friday, May 21, 2010

The Lawyers For the Parties in the Egan Trial (5/21/10)

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I have previously discussed here Judge Saylor's epic opinion in Egan knocking down two tax shelters as fraudulent and offered here her...
10 comments:

Update on Prospects for Swiss Parliamentary Approval of the Deal

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The NYT reports here that there are indications of a shift toward Parliamentary approval of the US / UBS / Swiss deal requiring UBS to turn...
Thursday, May 20, 2010

What the Egan Court (Judge Saylor) Said About the Lawyers (5/20/10)

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In the Egan case I discussed yesterday here , Judge Saylor was tough on the lawyers. I thought lawyers (who I presume are the principal rea...
6 comments:
Wednesday, May 19, 2010

Judge Finds Ambassador's Tax Shelter Transactions Bullshit (Actually Worse Than That) (5/19/10)

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I have previously noted here that a Claims Court judge, in effect, held that a tax shelter transaction was bullshit. Another case does the ...
11 comments:
Saturday, May 15, 2010

Fascinating WaPo Story on the Birkenfeld Saga (5/16/10)

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The May 16 edition of the Washington Post has a fascinating article on the Birkenfeld saga. David S. Hilzenrath, Swiss banker turned whistle...
1 comment:
Friday, May 14, 2010

En Banc Rehearing in Rigas - Scope of Conspiracy, Totality, and Double Jeopardy (5/14/10)

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Eearlier this week, the Third Circuit decided the Rigas case en banc. United State v. Rigas , 605 F.3d 194 (3d Cr. 2010), here .  I have pre...
Wednesday, May 12, 2010

IRS Noises About Attacking Kovel Arrangements

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Tax controversy attorneys often engage accountants to assist them in providing legal services to a client of the attorney facings civil or c...
Monday, May 10, 2010

Civil Statutes of Limitation for Abusive Tax Shelters (5/10/10)

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The statute of limitations rules for civil cases are: a. In non-TEFRA cases, the general rule is 3 years with two key exceptions in the ca...
1 comment:
Friday, May 7, 2010

Willfulness - What Does It Really Mean in Tax Cases? (5/7/10)

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The major tax crimes in the Internal Revenue Code require that the defendant act willfully. The standard for acting willfully is usually sta...
3 comments:
Thursday, May 6, 2010

Tax Practitioners Complain About Too Rigid Application of Voluntary Disclosure Program for Offshore Accounts

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The tax news media is abuzz yesterday and today about a letter from a group of tax attorneys significantly involved in advising and represen...
3 comments:
Monday, May 3, 2010

Foreign Financial Information - New Provisions

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The Foreign Account Tax Compliance Act ("FATCA") provisions of the recently enacted Hiring Incentives to Restore Employment Act (...
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Proposed Modifications to the Sentencing Guidelines -- More Latitude

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New more lenient Sentencing Guidelines, effective 11/1/2010. The new / proposed guidelines permit a judge more leeway to consider factors no...

DOJ Tax International Roadshow on Foreign Financial Accounts

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The international press report that the DOJ Tax Team -- Kevin Downing et al. -- are on the road to keep the press coverage rolling on the ne...