Tax Law

Recent Posts

Concerns and Strategies in Parallel Investigations
Posted on 7 Mar 2012 by Jack Townsend

One of the risks in eggshell civil audits -- where risk of criminal prosecution is material -- is the possibility of parallel investigations. Parallel investigations are simultaneous civil investigations and criminal investigations. These can involve... Read More

Plea Bargains Generally and in Tax Cases; Moneyball
Posted on 30 Mar 2012 by Jack Townsend

In two cases, the Supreme Court has recognized the central role of plea bargaining in the criminal system and held the right to effective assistance of counsel extends to advising the client in plea negotiations. Missouri v. Frye, ___ U.S. ___, 2012 U... Read More

Ninth Circuit Speaks on FOIA, but Ducks Fugitive Disentitlement
Posted on 17 Mar 2012 by Jack Townsend

A common parry in a tax criminal investigation or prosecution is to file a FOIA request with the IRS. The IRS / DOJ thrust is to resist. I provide at the end of this blog a general discussion of FOIA and the theories of resistance. In Shannahan v... Read More

  • Blog Post: Concerns and Strategies in Parallel Investigations

    One of the risks in eggshell civil audits -- where risk of criminal prosecution is material -- is the possibility of parallel investigations. Parallel investigations are simultaneous civil investigations and criminal investigations. These can involve the same agency and cooperating agencies (such as...
  • Blog Post: Ninth Circuit Speaks on FOIA, but Ducks Fugitive Disentitlement

    A common parry in a tax criminal investigation or prosecution is to file a FOIA request with the IRS. The IRS / DOJ thrust is to resist. I provide at the end of this blog a general discussion of FOIA and the theories of resistance. In Shannahan v. United States, ___ F.3d ___, 2012 U.S. App. LEXIS...
  • Blog Post: Plea Bargains Generally and in Tax Cases; Moneyball

    In two cases, the Supreme Court has recognized the central role of plea bargaining in the criminal system and held the right to effective assistance of counsel extends to advising the client in plea negotiations. Missouri v. Frye, ___ U.S. ___, 2012 U.S. LEXIS 2321 (2012) (enhanced opinion available...