Tax Litigation: The Week of June 6th, 2022, through June 10th, 2022 Musselwhite v. Commissioner, T.C. Memo. 2022-57 | June 8, 2022 | Ashford, J.| Dkt. No. 14380-16 Spencer v Commissioner, T.C. Memo. 2022-8 | June 7, 2022 |...more
Obstruction of Justice - Federal law penalizes the obstruction of justice. Because it involves intent to conceal criminal activity, courts have frequently referred to obstruction of justice as a crime of moral turpitude....more
A recent IRS Criminal Investigation press release announced an indictment against a businessman charged with defrauding the United States by not disclosing offshore assets, failing to report income to the IRS, and submitting...more
11/5/2021
/ Criminal Investigations ,
Department of Justice (DOJ) ,
FBAR ,
Foreign Bank Accounts ,
Income Taxes ,
Indictments ,
IRS ,
Offshore Funds ,
Tax Crimes ,
Tax Evasion ,
Tax Returns ,
Wire Fraud
Tax Court Litigation: The Week of September 13 – September 17, 2021 -
Donna M. Sutherland v. Comm’r, No. 3634-18, T.C. Memo 2021-110 | September 16, 2021 | Lauber | Dkt. No. 3634-18 -
Short Summary: This is an...more
11/2/2021
/ Business Taxes ,
Criminal Investigations ,
Employment Tax ,
Income Taxes ,
IRS ,
Joint and Several Liability ,
Joint Tax Returns ,
Spouses ,
Tax Court ,
Tax Liability ,
Tax Returns
What is the Report of Foreign Bank and Financial Accounts (FBAR)?
Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more
10/21/2020
/ Bank Secrecy Act ,
Civil Monetary Penalty ,
Criminal Investigations ,
Criminal Penalties ,
FBAR ,
Filing Requirements ,
FinCEN ,
Foreign Financial Accounts ,
Foreign Financial Institutions (FFI) ,
Government Investigations ,
IRS ,
Recordkeeping Requirements ,
Regulatory Authority ,
Statutory Authority ,
Tax Penalties
The IRS has been focused on enforcement efforts targeting conservation easement transactions. And IRS data indicates that more enforcement efforts lie ahead. The Senate Finance Committee, which has been engaged in a...more
Sensitive audits present the tax practitioner with unique challenges. They require the exercise of judgment and discretion, as well as an understanding of administrative procedure and even a command of constitutional and...more
10/1/2020
/ Accountants ,
Civil Liability ,
Criminal Investigations ,
Evidence Suppression ,
Fifth Amendment ,
Fourth Amendment ,
Internal Revenue Code (IRC) ,
IRS ,
Parallel Proceedings ,
Privileged Communication ,
Risk Mitigation ,
Tax Audits ,
Tax Fraud ,
Tax Penalties ,
Tax Returns