Tax Law

Recent Posts

Rambo Judge Grants Mercy to Convicted Foreign Account Holder
Posted on 13 Mar 2012 by Jack Townsend

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... Read More

Ninth Circuit Speaks on FOIA, but Ducks Fugitive Disentitlement
Posted on 17 Mar 2012 by Jack Townsend

A common parry in a tax criminal investigation or prosecution is to file a FOIA request with the IRS. The IRS / DOJ thrust is to resist. I provide at the end of this blog a general discussion of FOIA and the theories of resistance. In Shannahan v... Read More

Concerns and Strategies in Parallel Investigations
Posted on 7 Mar 2012 by Jack Townsend

One of the risks in eggshell civil audits -- where risk of criminal prosecution is material -- is the possibility of parallel investigations. Parallel investigations are simultaneous civil investigations and criminal investigations. These can involve... Read More

The Taxman Cometh: IRS Audit Focus on Middle Market Companies
Posted on 5 Apr 2012 by Asbury Law Firm

In a recent speech at the mid-year conference of the Tax Executives Institute, IRS Deputy Commissioner Steven T. Miller laid out the framework for the future of IRS corporate audits. To borrow Mr. Miller's own assessment, this is bad news for large... Read More

The Taxman Cometh: IRS Audit Focus on Middle Market Companies
Posted on 5 Apr 2012 by Asbury Law Firm

In a recent speech at the mid-year conference of the Tax Executives Institute, IRS Deputy Commissioner Steven T. Miller laid out the framework for the future of IRS corporate audits. To borrow Mr. Miller's own assessment, this is bad news for large... Read More

Rambo Judge Grants Mercy to Convicted Foreign Account Holder
Posted on 13 Mar 2012 by Jack Townsend

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... Read More

Ninth Circuit Speaks on FOIA, but Ducks Fugitive Disentitlement
Posted on 17 Mar 2012 by Jack Townsend

A common parry in a tax criminal investigation or prosecution is to file a FOIA request with the IRS. The IRS / DOJ thrust is to resist. I provide at the end of this blog a general discussion of FOIA and the theories of resistance. In Shannahan... Read More

Concerns and Strategies in Parallel Investigations
Posted on 7 Mar 2012 by Jack Townsend

One of the risks in eggshell civil audits -- where risk of criminal prosecution is material -- is the possibility of parallel investigations. Parallel investigations are simultaneous civil investigations and criminal investigations. These can involve... Read More