Collateral consequences often attend tax crimes investigations and prosecutions and even in circumstances that raise the risk of criminal investigation and prosecution. One collateral consequence is that the IRS wants to collect the tax dollars that the taxpayer owes, along with penalties and interest.The IRS has a number of collection tools -- most prominently the lien and levy. But the taxpayer can hide assets, particularly overseas assets that stymy collection. I write today on one of the tools available to the IRS to deal with such situations -- the little known writ ne exeat republica. I just read a case involving this writ. I suspect that many readers will not have heard of the writ. While the case I read this morning was unexceptional, I thought readers might find the introduction from my Tax Procedure book helpful as an introduction (footnotes omitted; footnotes can be reviewed the the downloadable text):
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