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

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Default Judgment Entered Against Convicted Defendant Who Agreed to Penalty (2/27/19)

11th Circuit Holds Relevant Conduct Loss for Guideline Calculation Can Be Less Than Loss Within Scope of Criminal Conspiracy (2/27/19)

Willful Blindness - Is It An Inference of Knowledge or Intent or Is It a Substitute (2/21/19)

10th Circuit Reverses Tax Money Laundering Conviction For Lack of Sufficiency of Evidence (2/21/19)

UBS Fined $4.2 Billion for Its French Foreign Account Escapades Raiding France of Taxes (2/20/19)

Federal Tax Procedure Book Update on Tax Crimes (2/20/19)

D.C. Circuit Rejects Defendant's Post Conviction Claims of Selective Prosecution, Actual Innocence and Attorney Conflict (1/23/19)

Court Applies Willful Blindness and Rejects Reliance on Friends Defense to FBAR Willful Penalty but Relieves Wife for One Year (1/23/19)

Ex UBS Banker Who Sold Client Data to Germany Convicted of Money Laundering and Acquitted of Bank Secrecy Violation (1/21/19)

Reminder of Key Differences Between Civil Fraud Penalties (1/17/19)

Court Dismisses 7 of 8 Counts Because of a Tolling Agreement Ambiguity (1/17/19)

Two Cases Involving Marinello (1/15/19)

Tax Crimes History -- The Fall of Vice-President Spiro Agnew and the Role of Tax Crimes (1/10/18)

On Restitution, Jury Factfinding and Original Meaning (1/8/19)

Ninth Circuit Rejects Spousal Testimonial Privilege for Foreign Bank Records (1/4/19)

Court of Federal Claims Holds that Not Reading The Schedule B Foreign Account False Answer Justifies FBAR Willful Penalty (12/28/18)

Article on Ethics Issues in Referring Clients to Foreign Aggressive Tax Planners/Enablers (12/27/18)

Tax Court Case Shows That the IRS Burden to Prove Fraud by Clear and Convincing Evidence Is Formidable Indeed (12/17/18)