Category archives: Tax Audits, Appeals & Litigation

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In a Criminal Tax Case the Taxpayer Must Press His Statute of Limitation Defense at Trial or It Will Be Waived

The statute of limitations for crimes in violation of the income tax laws is generally six years. However, the taxpayer cannot rely upon the statute of limitations as a defense if the taxpayer's counsel is asserting the statute of limitations defense for the first time on appeal. The taxpayer must press the statute of limitations defense during the trial.

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Court Finds That the Criminal Offense for a U.S. Resident’s Willful Failure to File an FBAR was Not Unconstitutionally Vague

Certain taxpayers who are citizens of foreign countries also have green cards granting them resident status in the United States. Some argue the laws regarding their obligation to file FBARs are unconstitutionally vague.

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The Applicable Federal Sentencing Guideline for a Violation of Internal Revenue Code Section 7212.

Section 7212 of the Internal Revenue Code punishes intentional attempts to interfere with the IRS’s administration of the Internal Revenue laws.

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