Criminal Tax Representation

February 9, 2017
What Does a Willful Failure to Report Offshore Accounts Really Mean?

What Does a Willful Failure to Report Offshore Accounts Mean?

On this blog, we have frequently discussed the willfulness standard as it relates to one’s duty to satisfy offshore account and asset disclosure obligations set forth […]
February 6, 2017
defendant with lawyer speaking to a judge in the courtroom trial

A Deliberate or Willful Blindness Jury Instruction Is Rarely a Good Sign for a Criminal Tax Defendant

Recently on the Federal Tax Crimes blog, the tax fraud case of Happy Asker was analyzed in the context of the willful blindness jury instruction given […]
December 2, 2016

DOJ Tax Division Discusses Tax Enforcement Priorities in 2016

Recently, the Principal Deputy Assistant Attorney General Caroline D. Ciraolo appeared and delivered prepared remarks at the American Bar Association’s 27th Annual Philadelphia Tax Conference. At […]
November 28, 2016

Think Social Standing Alone Will Protect you from Facing Criminal Tax Charges? Beware of the Pitfalls of Litigating on the Basis of Reputation

For many professionals such as doctors, accountants, engineers, and lawyers they may believe that their social standing, professional accomplishments, and reputation will immunize them from suspicion […]
November 17, 2016
Tax Crimes

Attorney Pleads Guilty to Tax Crimes

Attorney Pleads Guilty to Tax Crimes On this tax law blog, we frequently discuss the circumstances by which well-meaning individuals can start down a path that […]
October 31, 2016

How Does the IRS Develop a Delinquent Tax Return Case Against a Taxpayer

Taxpayers have many reasons and justifications for their failure to file taxes or their filing of tax returns or other documents that are deficient. Deficient tax […]