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Tuesday, February 27, 2018

IRS OVDP Declines-Withdrawals Campaign (2/27/18)

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Late last year, IRS LB&I announced here certain compliance "campaigns" for examinations.  Among the campaigns is the followin...
Monday, February 26, 2018

Coinbase Will Comply with JDS on Approximately 13,000 Customers for Bitcoin Transactions (2/26/18)

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I have reported before about the IRS John Doe Summons issued to Coinbase, a digital currency exchange.  See Court Orders Enforcement of John...
Saturday, February 24, 2018

Willful Blindness -- Does the Concept Expand the Statutory Element of the Crime of Knowledge? (2/24/18)

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In United States v. Carbins , 2018 U.S. App. LEXIS 3585 (5th Cir. 2018), here , the defendant "was convicted of one count of conspiracy...

Taxpayers with Failed Bullshit Tax Shelters Use FOIA to Try to Get Whistleblower, if any, Information (2/24/18).

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In Montgomery v. IRS , 2018 U.S. Dist. LEXIS 26313 (D. D.C. 2/20/18), here , taxpayers were caught using partnerships to claim large tax ben...

Congress Amends Tax Whistleblower Section, § 7623, to Clarify Broad Reading of the Award Base (2/24/18)

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Earlier this month, Congress amended the mandatory minimum tax Whistleblower award program to make clear that proceeds for purposes of the a...
Sunday, February 18, 2018

Recent Articles of Interest to Tax Crimes Fans (2/18/18)

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Fran Obeid, Passport Revocation Begins for 'Seriously Delinquent Tax Debt ,' 259 NYLJ No. 19 1/29/18), here . Jeremy Temkin, The ...
Tuesday, February 13, 2018

Third Circuit Affirms Summons Enforcement for Client Identity Information (2/13/18)

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In United States v. Martin , 2018 U.S. App. LEXIS 2526 (3d Cir. 2018) (nonprecedential), here , the Court of Appeals affirmed the district c...
Friday, February 9, 2018

IRS CI Focuses on Crytpocurrencies and Related Tax Evasion Schemes (2/9/18)

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David Voreacos, IRS Cops Are Scouring Crypto Accounts to Build Tax Evasion Cases (Bloomberg 2/8/18), here .  Excerpts: The U.S. Internal...
Wednesday, February 7, 2018

Second Circuit Makes Limited Remand for Sentencing Court to Explain Tax Crime Fine Variance to $10 Million from High Guideline Amount of $250,000 (2/7/18)

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I have previously written on the prosecution of Morris E. Zukerman for tax crimes.  I collect those prior blogs at the end of this blob.  I ...
Saturday, February 3, 2018

Problems with Restitution Based Assessment in Excess of Amount Due (2/3/18)

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In Choi v. United States , 2018 U.S. Dist. LEXIS 14393 (D. Md. 2018), here , the Court rejected an attempt by a defendant convicted of tax e...
Wednesday, January 31, 2018

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

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I blogged earlier about opinions on motions in limine in the Scali prosecution.  See Opinion on Discovery in Tax Evasion Case of Reliance ...

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

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In United States v. Murphy , 2018 U.S. App. LEXIS 1508 (9th Cir. 2018), unpublished, here , Murphy was convicted of four counts of filing fi...
Monday, January 29, 2018

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

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A good article on Cryptocurrencies and Taxes.  Rob Urban, Governments Worry That Cryptocurrencies Could Be the ‘Next Swiss Bank Account’ (...
Friday, January 26, 2018

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

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Chuck Rettig, here , a prominent and respected player in the tax controversy (including tax crimes) arena is reported to be Trump's pick...

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

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Some tax crimes related news on the Davos World Economic Forum, here . Switzerland asks US to swiftly conclude proceedings against Swiss b...

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

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In United States v. Scali , 2018 U.S. Dist. LEXIS 8137 (S.D. N.Y. 2018), here , the defendant was (bold=face supplied by JAT): charged in...
Thursday, January 25, 2018

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

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DOJ Tax announced here the sentence for Hyung Kwon Kim for an FBAR violation.  (Note that the announcement identifies the defendant as Huon...
Monday, January 22, 2018

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

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I recently wrote on Bradley Birkenfeld's continuing judicial efforts at some level of redemption or at least recompense.  See Birkenfel...