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Rambo Judge Grants Mercy to Convicted Foreign Account Holder

In United States v. Purpura , 2012 U.S. Dist. LEXIS 28748 (MD PA 2012), Judge Sylvia H. Rambo granted the convicted defendant's motion to withdraw his plea of guilty to two counts of tax perjury, Section 7206(2) related to a false answer to the Schedule B foreign account question. The opinion is...

Second Circuit Reverses and Vacates Convictions for Wire Fraud and Tax Evasion

In United States v. Litwok, ___ F.3d ___, 2012 U.S. App. LEXIS 8727 (2d Cir. 2012), here , the Second Circuit upset convictions for wire fraud and tax evasion, applying seeming settled principles. I address first the tax evasion convictions, although the Court addressed first the wire fraud conviction...

Convictions of Mail Fraud, False Claims and Conspiracy; Use of Offshore Accounts

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 guilty of three counts of mail fraud, seventeen...

Convictions of Mail Fraud, False Claims and Conspiracy; Use of Offshore Accounts

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 guilty of three counts of mail fraud, seventeen...

New Indictment of U.S. Tax Return Preparers & Enablers re Offshore Bank & Related Activity

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 With Helping Clients Evade Taxes By Hiding Millions...