Tax Crimes

How the IRS Reconstructs Income In Tax Fraud Cases
Listen In one of the climactic scenes from 1954’s On The Waterfront, Crime Commission prosecutors had to make their corruption case against union boss Johnny Friendly (a/k/a Michael Skelly) by convincing a reticent yet pure-hearted Terry Malloy to come forward and tell what he knew about corruption in the International Longshoremen’s Association, beginning with the …
Knowing When To Say When: Tax Practitioners & The Rules Governing the Giving of Legal Advice
Listen During its previous term, in a case that definitely took a back seat to the Affordable Care Act, same-sex-marriage, and the other high-profile disputes that the Supremes attempted to resolve, the High Court might have changed the way that doctors, dentists, accountants, lawyers, and other professionals have done business for decades. In North Carolina …
Overcoming The Pitfalls of Certifying Non-Willfulness When Applying To The Streamlined Compliance Program
Listen Of the recent changes made to the streamlined procedures, none have received as much attention – or stirred up as much debate – as the new rule requiring certification of non-willfulness as a condition for gaining entry. This blog focuses on the requirement of the new streamlined procedures that the failure to report income …
From Gumshoe To Gavel: The Required Records Doctrine And The Fifth Amendment Act-of-production Privilege Against Self-incrimination for Documents Relating to Foreign Accounts
Listen Although it didn’t have the panache of Dark Justice, a vastly underrated drama, in my humble opinion, the Law & Order franchise was once almost as ubiquitous as stars in the sky or grains of sand on the seashore. These shows featured solid writing and good acting, along with a half cop show/half lawyer …