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Saturday, December 28, 2019

More on Abusive Conservation Easements (12/28/19)

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Peter Reilly has a good discussion on an abusive conservation easement.  IRS Grinch Ruining Christmas For Syndicated Conservation Easements...

In Willful FBAR Collection Suit, District Court Rejects Reconsideration of Finding of FBAR Willfulness As Discovery Sanction (12/28/19)

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In an earlier Memorandum and Order in  United States v. Toth (D. Mass. Dkt. No. 15-cv-13367-ADB 10/15/18 ), GS here and CL here , the dist...
Wednesday, December 25, 2019

Tax Perjury, § 7206(1) Is a Different Crime than Perjury, 18 USC § 1621 (12/25/19)

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Yesterday, I was updating the working draft of my Federal Tax Procedure Book, here , for the 2020 editions to make a point about § 7206(1) h...
Saturday, December 21, 2019

On Informing the Jury of Jury Nullification and Sentencing Consequences (12/21/19; 12/22/19)

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In United States v. Manzano , ___ F.3d ___ (2d Cir. 2019), here  (2d Cir.) or here (Google Scholar), a nontax case, the Second Circuit addr...
Friday, December 20, 2019

Coutts & Co. Ltd. Enters an Addendum to its Swiss Bank Program Category 2 NPA (12/20/19)

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I previously reported that Coutts & Co. Ltd. (“Coutts”) had entered a NonProsecution Agreement (“NPA”) with DOJ Tax under the DOJ Swiss ...
Thursday, December 19, 2019

Eleventh Circuit Sustains IRS Summons Issued For French Tax Investigation (12/18/19)

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[This is a cut and paste of a posting on my Federal Tax Procedure Blog] In  Redfern v. United States  (11th Cir. Dkt. 19-12649 12/17/19) (...
Sunday, December 15, 2019

Court Grants Summary Judgment on FBAR NonWillful Penalty Collection Suit (12/15/19)

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In United States v. Agrawal (E.D. Wisc. Dkt. 18-C-0504 Order Dtd. 12/9/19) (CL here and GS here ), the Court granted summary judgment to t...
Friday, December 13, 2019

Defendant (A Former Tax Lobbyist and DOJ Tax Attorney) Sentenced to 1 Year for Tax Perjury Conviction (12/13/19)

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I previously blogged on the plea agreement for James F. Miller, a former tax lobbyist (and former DOJ Tax attorney).  Former DOJ Tax Attorne...
Wednesday, December 11, 2019

DOJ Reaches DPA with HSBC Switzerland (12/11/19)

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DOJ Tax has announced a deferred prosecution agreement (“DPA”) with HSBC Switzerland in which “HSBC Switzerland admitted to conspiring with ...

Interesting Retrial After Cheek Defense Based on Religious Objection to Use of Tax Collections (12/11/19)

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I picked up this article: After mistrial, judge says he made mistake in allowing man to argue religious objection to filing tax returns (Th...
Monday, December 9, 2019

Reuters Reports EU Considers Further Tax Haven Listing (12/9/19)

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Reuters has this report:  EU to consider tougher tax haven listing (12/6/19), here .  Key excerpts: A group of European Union countries ...
Wednesday, December 4, 2019

Swiss High Court Approves UBS Disclosure of French Account Holders and Outlines Requirements (12/4/19)

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According to a Reuters report, Switzerland's highest court has outlined the requirements for foreign countries seeking Swiss assistance...
Sunday, December 1, 2019

The Missing Witness Negative Inference and the Impeachment Proceedings (12/1/19)

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A couple of days ago, I wrote on the D.C. Circuit Court’s rejection of another Bullshit Tax Shelter.  D.C. Circuit Swats Down Bullshit Tax S...
Friday, November 29, 2019

D.C. Circuit Swats Down Bullshit Tax Shelter (11/29/19)

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In Endeavor Partners, LLC v. Commissioner , ___ F.3d ___ (D.C. Cir. 2019), here , the Court affirmed the Tax Court’s strike-down of yet anot...
Monday, November 25, 2019

New LB&I Campaign for Post OVDP Compliance (11/25/19)

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I previously reported that IRS LB&I included among its “campaigns” OVDP Declines-Withdrawals Campaign.  IRS LB&I "Campaigns...
Tuesday, November 19, 2019

RICO Claim Dismissed Against Bullshit Tax Shelter Promoters (11/19/19; 11/22/19)

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In Menzies v. Seyfarth Shaw LLP , __ F.3d ___ (7th Cir. 2019), here , the Court dismissed a RICO claim arising out of an alleged fraudulent ...
Sunday, November 17, 2019

Report of IRS Criminal Interest in Captive Insurance Shelters (11/17/19)

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It is reported that the IRS is looking to make criminal referrals to CI in § 831(b) captive insurance cases.  Jay Adkisson, IRS Suggests Cri...
Wednesday, November 13, 2019

Sixth Circuit Holds that Courts Cannot Enjoin IRS From Receiving or Using Alleged Confidential Info from Former Attorney (11/13/19)

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In Gaetano v. United States , 2019 U.S. App. LEXIS 33164 (6th Cir. 2019), here , the Gaetanos (husband and wife) sued the United States to e...