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Third Circuit Discussion on Violation of Legal Duty with Other Reasonable Interpretations of Duty (1/13/21)

In United States v. Harra, ___ F.3d ___ (3rd Cir. 2021), here, the Court held (as summarized at the opening of the opinion): When a defendant is charged with false reporting based on an ambiguous reporting requirement, what is the prosecution’s burden at trial as to the element of falsity? Is it sufficient for the […]

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Update on Brockman Indictment (11/11/20)

I previously posted on the Brockman indictment in ND CA.  One Big Fish Indicted and Lesser Big Fish Achieves NPA for Cooperation (Federal Tax Crimes Blog10/16/20), here. There have been some developments via pre-trial motion practice that I note in this blog.  (Readers may follow these and future developments either on PACER (requiring fees) or […]

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The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20)

In an ABA Tax Section Court Procedure Virtual meeting on Wednesday, there was a one-hour discussion of ethical issues in handling a matter in the Tax Court.  The participants in the discussion were: • Judge L. Paige Marvel, United States Tax Court, Washington, D.C.• Elizabeth G. Chirich, Chief, Branch 1, Procedure & Administration, IRS Office […]

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The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 7/28/20)

In an ABA Tax Section Court Procedure Virtual meeting on Wednesday, there was a one-hour discussion of ethical issues in handling a matter in the Tax Court.  The participants in the discussion were: • Judge L. Paige Marvel, United States Tax Court, Washington, D.C.• Elizabeth G. Chirich, Chief, Branch 1, Procedure & Administration, IRS Office […]

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The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 7/29/20)

In an ABA Tax Section Court Procedure Virtual meeting on Wednesday, there was a one-hour discussion of ethical issues in handling a matter in the Tax Court.  The participants in the discussion were: • Judge L. Paige Marvel, United States Tax Court, Washington, D.C.• Elizabeth G. Chirich, Chief, Branch 1, Procedure & Administration, IRS Office […]

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The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 8/2/20)

In an ABA Tax Section Court Procedure Virtual meeting on Wednesday, there was a one-hour discussion of ethical issues in handling a matter in the Tax Court.  The participants in the discussion were: • Judge L. Paige Marvel, United States Tax Court, Washington, D.C.• Elizabeth G. Chirich, Chief, Branch 1, Procedure & Administration, IRS Office […]