September 5, 2014

Is it tax evasion if my W-4 contains false statements?

Without knowing more about your specific facts and circumstances, this question cannot be answered. However, IRC Section 7201 finds a person liable for tax evasion when […]
August 12, 2014

IRC §7201 attempt to evade vs. common-law crime of attempt

No, IRC Section 7201’s definition of “attempt to evade” is materially different from “attempt” crime of common-law. This was one of the holdings of the Supreme […]
April 8, 2014

What is a tax that was “due and owing.”

Like almost all areas of law, especially tax law, there are nuances and exceptions. The government must prove beyond a reasonable doubt three basic things to […]
March 27, 2014

What are the common issues that non-filers face?

Each year the IRS receives more than 150 million tax returns filed by individuals and businesses. But despite the nearly universal obligation to file taxes due […]
March 21, 2014
California’s Taxpayer Transparency and Fairness Act of 2017

CPA aiding or assisting the filing of a false return

Generally, this statute does not apply just to tax preparers but anyone who causes a false return to be filed. Accordingly, the CPA should be aware […]
March 21, 2014

Defenses for tax crimes of a taxpayer or tax preparer

Willfulness is defined under the law as a voluntary and intentional violation of a known legal duty and several defenses focus on preventing the government from […]