The United States Attorney's office has announced the sentencing of "Dennis Duban, a Los Angeles-based accountant and tax return preparer." The press release is here . He was sentenced to 24 months in prison pursuant to his plea for one... Read More

In United States v. Hom , [ enhanced version available to lexis.com subscribers ], 2014 U.S. Dist. LEXIS 77489 (N.D. CA 2014), here , Hom was an online gambler who held accounts at two online poker companies, PokerStars and PartyPoker. He used a financial... Read More

U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December... Read More

By Karen Yip, LexisNexis Federal & International Tax Analyst The IRS requires the Report of Foreign Bank and Financial Accounts, TD F 90-22.1 (commonly known as the Foreign Bank Account Report, or "FBAR"), when a U.S. person has a financial... Read More

By Karen Yip, LexisNexis Federal & International Tax Analyst The IRS requires the Report of Foreign Bank and Financial Accounts, TD F 90-22.1 (commonly known as the Foreign Bank Account Report, or "FBAR"), when a U.S. person has a financial... Read More

According to a DOJ Press Release, Curtis Morris and Richard Kellog Armstrong were convicted of "for mail fraud, filing false claims against the United States and conspiracy to file false claims against the United States." "Morris was found... Read More

By Robb Chase and Amanda Pugh On February 14, 2012, the Department of Treasury's Financial Crimes Enforcement Network (FinCEN) issued Notice 2012-1, which extended the filing deadline for both the 2010 and 2011 Report of Foreign Bank and Financial... Read More

The National Taxpayer Advocate's report discussed in the preceding blog has a component titled Most Litigated Issues: Case Advocacy, Appendices, here . In that component, the NTA discussed the Williams case (see report at pp 601 - 603). The discussion... Read More

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

Readers of this blog should be familiar with the name Ty Warner. He is the billionaire who cheated on his U.S. taxes big time (the financially big can cheat big) and, in addition, willfully failed to file the FBARs. He pled guilty to a reduced set of... Read More

U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December... Read More

By Karen Yip, LexisNexis Federal & International Tax Analyst The IRS requires the Report of Foreign Bank and Financial Accounts, TD F 90-22.1 (commonly known as the Foreign Bank Account Report, or "FBAR"), when a U.S. person has a financial... Read More

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

By Veronica R. Johnson Did you know that if you have a bank account outside of the United States, you may be required to file a Treasury Form 90-22.1 with the U.S. Treasury every year? There are strict penalties in place for those who fail to file this... Read More

The National Taxpayer Advocate's report discussed in the preceding blog has a component titled Most Litigated Issues: Case Advocacy, Appendices, here . In that component, the NTA discussed the Williams case (see report at pp 601 - 603). The discussion... Read More