In Harrington v. Commissioner, T.C. Memo. 2021-95, GS here, the Court (Judge Lauber) determined deficiencies and the civil fraud penalty for a taxpayer who played the offshore account game (a pernicious variation of the audit lottery) and lost. The taxpayer was a UBS depositor; UBS disclosed the taxpayer’s information and documents. And the rest was, […]
In Harbor Healthcare System, L.P. v. United States, 2021 U.S. App. LEXIS 20988 (5th Cir. 7/15/21) (Unpublished), here, a nontax case, the Court had this interesting footnote (Slip Op. 6 n. 1): n1 The government asserts several times in its brief that “Harbor is a subject of a grand jury proceeding.” Under Rule 6 […]
[embedded content] “CBS This Morning,” in partnership with KHN and NPR, interviews Phil Gaimon, a cyclist who had hoped to be in Tokyo next week as a competitor in the track events on the USA Cycling national team. Instead, a crash on the velodrome track in Pennsylvania in 2019 ended his Olympic dream and left […]
Not so long ago, laws governing abortion in Massachusetts and Rhode Island were far more restrictive than those in the Deep South, as state legislators throughout New England regularly banned the procedure, no matter the circumstances, during the 1960s and ’70s. Nowadays, however, the American South represents a hub of anti-abortion fervor, home to a […]
In The Matter of the Tax Liabilities of John Does, United States Taxpayers (S.D. N.Y. 7/15/21), CL here, the Court ordered the service of a John Doe Summons upon several prominent financial services businesses related to taxpayers who may have used an offshore law firm, Panama Offshore Legal Services for U.S. tax noncompliance. I first […]
Claim: “CDC has just announced they will revoke the emergency use authorization of the RT-PCR tests first introduced in 2/20. … Translation: They’ve been adding flu cases to Covid cases when using that test.” Facebook post, July 25, 2021 Posts circulating on Facebook and Instagram claim the Centers for Disease Control and Prevention will stop […]
There are collateral consequences to being convicted of a tax crime (as well as other crimes). Some of the collateral consequences for tax crimes are covered in Michael Saltzman and Leslie Book, IRS Practice and Procedure (Thomsen Reuters 2015), ¶ 12.06 Collateral Consequences. (Note, I am the principal author of Chapter 12, titled Criminal Penalties […]
Can’t see the audio player? Click here to listen on SoundCloud. You can also listen on Spotify, Apple Podcasts, Stitcher, Pocket Casts or wherever you listen to podcasts. Predictions of a “hot vax summer” that would let Americans who had their covid immunizations celebrate the waning of the pandemic are turning out to have been […]
Upon first inspection, the mutations in the highly contagious delta covid variant don’t look that worrisome. For starters, delta has fewer genetic changes than earlier versions of the coronavirus. “When people saw that the epidemic in India was driven by delta, they did not suspect it would be so bad or overtake other variants,” said […]
When Kayla Kjelshus gave birth to her first child, the infant spent seven days in the neonatal intensive care unit, known as the NICU. This stressful medical experience was followed by an equally stressful financial one. Because of an obscure health insurance policy called the “birthday rule,” Kjelshus and her husband, Mikkel, were hit with […]