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Panama Papers Produces Another Plea and Conviction, Previously Sealed (3/7/21)

The International Consortium of Investigative Journalists (“ICIJ”) has this release announcing the plea, conviction and sentencing of a person, Joachim Alexander von der Goltz, implicated in the Panama Papers disclosures.  As reported, this is the third person brought to justice pursuant to the Panama Papers disclosures.  One of the others convicted was Joachim Alexander’s father, […]

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Tax and FBAR Crimes and Related Naturalization Crimes (2/11/21)

DOJ issued this Press Release:  Former Florida Resident Indicted for Tax Evasion and Failing to Report Foreign Bank Accounts (2/10/21), here.  The thing that, I think, should be most interesting to readers are the naturalization charge which, apparently, relates to the tax charges (at least the offshore income and accounts).  The key excerpts of the […]

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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 […]