eBook | Foreign Asset Reporting: Navigating the Choppy Financial Seas.

Al Capone: The Man, The Myth, The Legend

Al Capone, the American gangster who was convicted of tax evasion, was one of the most notorious mob figures of the twentieth century. He was a captivating figure who infatuated the American public. Ever since his death, Capone’s personality and character have been used in fiction — both on camera and on the stage — as a […]

Criminal Tax Liabilities & Sentencing Part III: The Pre-sentence Investigation Report

In this podcast, I discuss the pre-sentence investigation report. Below is a quick and dirty outline: After conviction and prior to sentencing, a probation officer will interview the def. and prepare a PSR. In the PSR, the probation officer will: Calculate the defendant’s offense level and criminal history category, State the resulting sentencing range and […]

HOW THE IRS RECONSTRUCTS INCOME IN TAX FRAUD CASES – A WEBINAR

This is a webinar that I presented in partnership with CPA Academy. I’m honored to lecture for such a fine CPE provider. For those who are interested in obtaining CPE credit, click here to sign up. Below is more information about the program: Course Description In one of the climactic scenes from 1954’s On The […]

Criminal Tax Liabilities & Sentencing: Part I

This is the first of several parts. There is a lot of information to discuss that it might feel like drinking water out of a fire hydrant. Sentencing issues are arguably the most important part of a federal criminal tax case. Because the likelihood of conviction is so high, the best that defense counsel can do […]

Fifth Amendment Privilege: The Balance Between Progress and Taxpayer Protection

I wish to graciously acknowledge the work of Valerie Vlasenko, Esq. from the law firm of Agostino & Associates, P.C. whose keen insight and innovative thinking as reflected in her article entitled, “Fifth Amendment Privilege in Tax: How to Keep the Case Moving While Protecting the Taxpayer,” has proven invaluable. Her guidance offers a practical […]