IRS Authority to Settle After Referral to DOJ Tax

IRS Authority to Settle After Referral to DOJ Tax

I point readers to an excellent blog by Peter Reilly -- An Isley Brother In Tax Court - Does Tax Crime Pay (Forbes Taxes 11/10/13), here. Peter discusses the recent decision [enhanced version available to lexis.com subscribers] in Isley v. Commissioner, 141 T.C. No. 11 (2013), here. I refer readers to Peter's excellent discussion of the issues in the case. I address here only the issue I think most relevant to Tax Crimes enthusiasts. However, the case does have some other tax procedure issues that I recommend to readers.

The taxpayer, Ronald Isley, was one of the famous Isley Brothers (Wikipedia entry here) whose:

musical genres included rhythm and blues, doo-wop, funk, and contemporary R&B. Various versions of the group had top 40 singles and/or top 20 albums during a period stretching from 1962 to 2006, which ultimately led to various accolades including the induction of petitioner and four of his brothers into the Rock and Roll Hall of Fame. Late in his career, petitioner focused on solo work, and as late as 2011 he was still performing with his younger brother Ernie.

Over the many years, the taxpayer made a lot of money and was a chronic tax delinquent. I won't get into the taxpayer's skirmishes with the IRS and ultimately DOJ Tax; suffice it to say that IRS referred his case to DOJ Tax for criminal prosecution, he was prosecuted, convicted by a jury, and was sentenced on 9/1/06 "to 37 months' imprisonment and, upon release from imprisonment, placing petitioner on "supervised release for a term of three years" (three-year probationary period)." The following are the pertinent terms of the sentencing court's judgment and probation commitment order (JPC order) which....

View Jack Townsend's opinion in its entirety on the Federal Tax Crimes blog site.

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