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Tax Court Finds IRS Compliance Officer Liable for Civil Fraud Penalty

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 tax fraud that will identify, particularly for laymen...

Tax Court Finds Fraud Based, in Part, On Negative Inference from Fifth Amendment Assertion

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 fraud, the proper tax treatment of money taken by...

Suellen Wolfe on Offshore Voluntary Disclosure Initiatives

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 failing to report income earned on financial...