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Showing posts with label 6663. Show all posts
Showing posts with label 6663. Show all posts
Saturday, November 20, 2021

Civil Liability for Conduct that is Acquitted in Criminal Case (11/20/21)

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 The Kyle Rittenhouse acquittal on all counts is in the news.  Acquittal or conviction (on some or all counts) was sure to become a politica...
Monday, October 26, 2020

Two Updates on Syndicated Conversation Easements (10/26/20)

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I report in brief two recent developments in syndicated easement cases that have been the focus of so much IRS audit and investigation activ...
Tuesday, September 1, 2020

District Court Sustains FBAR Willful Penalty But Rejects Fraudulent Failure to File Penalty for Income Tax (9/1/20)

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 In  United States v. DeMauro  (D. N.H. Dkt. 17-cv-640-JL Order and Verdict After Bench Trial dtd. 8/28/20), CL  here , the Court sustained ...
Thursday, January 16, 2020

Criminal Tax Evasion and Civil Fraud–If Found by the Trier, Can There be a Reasonable Cause/Good faith Defense (1/16/20; 1/17/20)

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I have blogged several times on my Federal Tax Crimes Blog about how the “good faith” defense is subsumed in the definition of willfulness f...
Friday, September 13, 2019

Does Failure to Assert Graev 6751(b) Issue in Claim for Refund Foreclose Asserting in Refund Suit? (9/13/19)

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For some reasons, although I had this case in my database, I had not reported on it.  Ginsburg v. United States , 123 A.F.T.R.2d 2019-553 (M...
Thursday, July 11, 2019

More on Litigation and IRS Raising Civil Fraud New Matter (7/11/19)

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My last post involved the IRS raising the civil fraud penalty as new matter by amended answer and prevailing. IRS Raises Fraud In Tax Court ...
Tuesday, July 9, 2019

IRS Raises Fraud In Tax Court Amended Answer and Prevails (7/9/19)

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In  Wegbreit v. Commissioner , T.C. Memo. 2019-82,  here , the taxpayer husband went through some deceptive shenanigans to hide the income f...
Thursday, October 3, 2013

Court of Federal Claims Holds that Unlimited Civil Statute of Limitations Requires Taxpayer's Fraud (10/3/13)

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In BASR Partnership et al. v. United States , 113 Fed. Cl. 181 (2013), here , the Court of Federal Claims (Judge Susan G. Braden), in a part...
Wednesday, September 25, 2013

Taxpayer Judicially Estopped from Refund For Taxes Admitted in Plea Agreement (9/25/13)

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In  Mirando v. United States , 2013 U.S. Dist. LEXIS 135659 (ND OH 2013), the taxpayer pled guilty to conspiracy and tax evasion.  The plea ...
Tuesday, February 26, 2013

Yet Another Bullshit Tax Shelter Bites the Dust (2/26/13)

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In  Crispin v. Commissioner , ___ F.3d ___, 2013 U.S. App. LEXIS 3852 (3d Cir. 2013),  here , as had the Tax Court, the Third Circuit smacke...
Saturday, January 19, 2013

Tax Court Applies Willful Blindness to Find Civil Fraud by Clear and Convincing Evidence (1/19/13)

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I have posted a discussion on this topic on my Federal Tax Crimes blog.  The title is the same, Tax Court Applies Willful Blindness to Find ...
Tuesday, October 9, 2012

Render Unto Caesar -- Another Intersection of Alleged Religion and Tax (10/9/12)

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In  Hovind v. Commissioner , T.C. Memo. 2012-281,  here , the Tax Court decided decided that the taxpayer had "had unreported Schedule ...
Sunday, September 9, 2012

Case on Collateral Estoppel [Issue Preclusion] as to Civil Fraud (9/9/12)

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I have just posted on my Federal Tax Crimes Blog a short discussion of the recent case of Anderson v. Commissioner , 2012 U.S. App. LEXIS 18...
Thursday, August 2, 2012

Civil Tax Fraud - IRS Burden of Proof and Negative Inference from Fifth Amendment Silence (8/2/12)

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In the Tax Procedure class, we study fraud with respect to tax obligations.  Fraud has criminal and civil components.  Although we cover bri...