Tax Law

Recent Posts

Tax Court Finds Fraud Based, in Part, On Negative Inference from Fifth Amendment Assertion
Posted on 14 Aug 2012 by Jack Townsend

In Loren-Maltese v. Commissioner, T.C. Memo. 2012-214 , the Tax Court introduces the legal issues as follows: It's the facts that make this case interesting, but there are three issues of law that color its background: the general rules of tax... Read More

Tax Protestors Alive and Well and Living in Canada
Posted on 16 Apr 2012 by Allison Christians

The tax protestor movement is alive and well in Canada and getting some publicity just in time to serve as a warning to Canadian taxpayers readying their annual returns.* I read with interest the recent case of Russell Porisky and his wife Elaine Gould... Read More

Pastor Going to Trial for Tax Charges Predicted Jesus Would Come On May 27
Posted on 31 May 2012 by Jack Townsend

I have previously blogged on Ronald Weinland. See Controversial Pastor, Self Proclaimed Prophet, Indicted re Income from Church Offerings and Offshore Accounts (11/21/11), here . My impression from afar is that he is just a charlatan (see here ) in the... Read More

New Indictment of U.S. Tax Return Preparers & Enablers re Offshore Bank & Related Activity
Posted on 18 Jun 2012 by Jack Townsend

In a First Superseding Indictment, here , filed June 14, 2012 in CD CA, three principals of a tax return preparation service, United Revenue Service ("URS") were indicted. The DOJ Tax Press Release is here, Three Tax Return Preparers Charged... Read More

Tax Court Finds IRS Compliance Officer Liable for Civil Fraud Penalty
Posted on 10 Jul 2012 by Jack Townsend

Readers interested in the risks of being audited with respect to income tax noncompliance arising from foreign assets (particularly financial accounts) often ask what it takes for the IRS to prove fraud. I am aware of no standard litmus test of civil... Read More

Tax Cheat Sentenced to Making Pizza
Posted on 29 Oct 2010 by David Brunori

Here is a great story from the Buffalo News . Joe Jacobbi owns a popular pizza joint in Buffalo. . . . But Joe has a tax problem. It seems that he was collecting sales tax on his pizza sales and not paying the tax dollars over to the state. . . . Joe... Read More

Defendant Waives Attorney-Client Privilege by Asserting Reliance on FBAR Advice Defense
Posted on 23 Jul 2012 by Jack Townsend

In United States v. Kerr, 2012 U.S. Dist. LEXIS 98836 (D AZ 2012) , a case with two U.S. taxpayers and their lawyer as defendants, the court held that the indicted U.S. taxpayers' claims of reliance constituted a waiver of their attorney-client privilege... Read More

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

  • Blog Post: Tax Cheat Sentenced to Making Pizza

    Here is a great story from the Buffalo News . Joe Jacobbi owns a popular pizza joint in Buffalo. . . . But Joe has a tax problem. It seems that he was collecting sales tax on his pizza sales and not paying the tax dollars over to the state. . . . Joe gets caught and the state says he owes over $100,000...