Federal Tax Crimes

Jack Townsend offers this blog on Federal Tax Crimes principally for tax professionals and tax students. It is not directed to lay readers -- such as persons who are potentially subject to U.S. civil and criminal tax or related consequences. LAY READERS SHOULD READ THE PAGE IN THE RIGHT HAND COLUMN TITLE "INTENDED AUDIENCE FOR BLOG; CAUTIONARY NOTE TO LAY READERS." Thank you.

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Jack Townsend: Houston, TX, United States

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Federal Tax Crimes

Pages

Opinions on Motions in Limine Regarding Government Use of Defendant's Former Tax Lawyer as Witness Against Him (1/31/18)

Ninth Circuit Rejects Defendant's Attack on Sentencing Calculations (1/31/18)

The Rise of Cryptocurrencies for Tax Avoidance/Evasion (1/29/18)

Tax Controversy Attorney Rettig To Be Nominated IRS Commissioner (1/26/18)

Tax Crimes Related News from Davos (1/26/18)

Opinion on Discovery in Tax Evasion Case of Reliance on Counsel Documents (1/26/18)

Offshore Account Defendant Sentence with Court Accepting Government's New Position on Guidelines Calculations (1/25/18)

Birkenfeld Loses Suit Against UBS in New York Supreme Court (1/22/18)

Perjury and False Statements -- Is There a Literal Truth Defense? (1/17/18)

Fourth Circuit NonPublished Opinion Offers Little on Willful Blindness Instruction (1/15/18; 1/17/18)

Presence or Absence of Tax Deficiency, Although Not an Element of Tax Perjury (§ 7206(1)), Crime, May be Relevant to the Materiality Element (1/14/18)

Two "Investors" in BullShit Tax Shelters Lose FTCA Claims on Appeal (1/13/18)

Fifth Circuit Adopts Disjunctive Reading Permitting § 7202 Conviction for Failure to Pay Over After Properly Accounting (1/12/18)

Court of Appeals Rejects Arguments as to Improper Admission of Evidence (1/6/18)

NYT Article on the Stefan Buck, Offshore Account Enabler, Acquittal (1/6/18)

Swiss Court Ruling Blocking the Disclosure to U.S. Tax Authorities of Individual Enabler Information (1/5/18)

Pre-Trial Decisions on Motion to Suppress (Tweel Issue) and Dismiss Tax Obstruction Count (Marinello Issue) (11/5/17)

Article with Predictions, Properly Hedged, on Outcome in Marinello (12/28/17)