Tax Law

Recent Posts

Suellen Wolfe on Offshore Voluntary Disclosure Initiatives
Posted on 15 Aug 2012 by LexisNexis Tax Law Community Staff

By Suellen Wolfe, J.D., LL.M.* The Internal Revenue Code requires U.S. taxpayers to report income and pay taxes on worldwide income. [ IRC §§ 61 , 861 , 862 , 863 , 864 , 865 . See also, IRS Publication 17 at Part Two, 5 (2011).] Intentionally... Read More

Tags: offshore bank accounts , civil penalties , civil fraud , Sullen Wolfe , Criminal penalties , 7206 , 7207 , offshore voluntary disclosure , 7201 , 7203 , 6038

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

Tags: campaign funds , civil fraud , money laundering , self-incrimination , tax evasion , tax fraud , Fifth Amendment , negative inference , Federal Taxation , inferences

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

Tags: IRS , tax audits , Quinn v. Commissioner , civil fraud , tax evasion , tax fraud , tax court , tax deductions , income tax noncompliance , Federal Taxation

Suellen Wolfe on Offshore Voluntary Disclosure Initiatives
Posted on 15 Aug 2012 by LexisNexis Tax Law Community Staff

By Suellen Wolfe, J.D., LL.M.* The Internal Revenue Code requires U.S. taxpayers to report income and pay taxes on worldwide income. [ IRC §§ 61 , 861 , 862 , 863 , 864 , 865 . See also, IRS Publication 17 at Part Two, 5 (2011).] Intentionally... Read More

Tags: offshore bank accounts , civil penalties , civil fraud , Sullen Wolfe , Criminal penalties , 7206 , 7207 , offshore voluntary disclosure , 7201 , 7203 , 6038

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

Tags: IRS , tax audits , Quinn v. Commissioner , civil fraud , tax evasion , tax fraud , tax court , Jack Townsend , tax deductions , income tax noncompliance , Federal Taxation

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

Tags: campaign funds , civil fraud , money laundering , self-incrimination , tax evasion , tax fraud , Fifth Amendment , Jack Townsend , negative inference , Federal Taxation , inferences