Taxpayers routinely ask me if they can go to jail for not paying their federal income taxes. Admittedly, the bar is not that high for felony tax evasion—the government must only prove three elements: (i) willfulness; (ii)...more
Taxpayers who employ workers have obligations under federal law to withhold and remit federal employment taxes to the IRS. In addition to this withholding and payment requirement, federal law also imposes certain reporting...more
The Administrative Procedure Act.
The Internal Revenue Code (the “Code”) contains over one hundred different civil penalties for various acts or failures to act. For example, Section 6707A requires taxpayers, in certain...more
In civil and in criminal cases, the Government must generally act within a certain prescribed time to take action against taxpayers. In legal parlance, this period of time is known as the “statute of limitations.” The...more
2/8/2022
/ Criminal Liability ,
Foreign Bank Accounts ,
Government Investigations ,
Income Taxes ,
Indictments ,
IRS ,
Jury Instructions ,
OVDP ,
Statute of Limitations ,
Tax Evasion ,
Tax Liability ,
Tax Planning
In many cases, taxpayers attempt to transfer assets or property to third persons to shield those assets and property from the federal tax lien or federal tax levy. Predictably, the IRS has various tools at their disposal to...more
8/17/2021
/ Criminal Liability ,
FDCPA ,
Fraudulent Transfers ,
Income Taxes ,
IRS ,
Statute of Limitations ,
Tax Evasion ,
Tax Levy ,
Tax Liability ,
Tax Liens ,
Tax Planning ,
Transfer of Assets
Federal tax cases against the IRS can be difficult. Even procedurally so. Under the pay-first, litigate-later rule, taxpayers are generally required, prior to filing suit against the United States: (1) to full pay the...more
5/20/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Federal Jurisdiction ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties