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 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 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 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