On November 16, 2018, Matthew D. Lee will moderate a panel at the annual White Collar Practice seminar sponsored by the Pennsylvania Association of Criminal Defense Lawyers. With the Special Counsel’s high-profile indictments of Paul Manafort as context, Matt’s panel will address the latest developments in tax and money laundering cases, with a particular emphasis
IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions
Ian M. Comisky and Matthew D. Lee have authored a Journal of Taxation article entitled “IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions.” In their article, Ian and Matt write that its recent decision in Marinello, the U.S. Supreme Court dealt taxpayers a rare win by significantly constraining the government’s ability to employ
Charles Rettig – From Private Practice to President Trump’s Nominee for IRS Commissioner
The White House released a statement on February 8, 2018 that President Trump nominated Charles Rettig as the new Commissioner of Internal Revenue Code for the remainder of a five year term that began in November 2017. Unlike other recent presidential nominees that may have ignited fierce debate among political parties, Rettig’s nomination has been
With Tax Season Fast Approaching, IRS Secures Guilty Plea in High-Profile Tax Case Involving Reality TV Star “The Situation”
The Internal Revenue Service has announced that the nation’s tax season will begin on Monday, January 29, 2018. As is typically the case, the annual opening of tax season is accompanied by well-publicized enforcement actions intended to warn potential tax cheats of the perils of filing a false tax return. This year is no different,
BNA Reports That Tax-Zapping Software Costs States $21 Billion in Taxes Annually
BNA’s Michael J. Bologna and Paul Shukovsky have written a comprehensive article about a pervasive problem facing state tax auditors: the use by restaurants and other cash-intensive businesses of electronic revenue suppression software, commonly referred to as “Zappers.” We have previously blogged about efforts by state and federal tax authorities to crack down on the
Connecticut Announces Arrest of Restaurant Owner for Using “Zapper” Tax Suppression Software
Connecticut’s Department of Revenue Services (DRS) has arrested and charged a New Haven restauranteur with various offenses for using sales tax suppression software. According to a press release announcing the charges, this is the first time the State of Connecticut has charged an individual for using “zapper” software, which it describes as “a type of
No Rest for the Weary: Offshore Tax Evasion Crackdown Continues with Flurry of Mid-Summer Activity
Dashing any thought that they were taking a hiatus from investigating and prosecuting taxpayers with secret offshore bank accounts and the bankers that helped them, the Justice Department and Internal Revenue Service have unleashed an avalanche of new enforcement activity in the final days of July. Since 2008, the government has criminally charged more than
DOJ’s Prosecution of Health Care Exec Illustrates Unique Intersection of Securities & Employment Tax Fraud Schemes
In a recent criminal prosecution of a medical doctor/entrepreneur for defrauding his company’s shareholders, the government employed a novel theory of securities fraud premised, in part, upon the defendant’s failure to pay federal employment taxes withheld from his employees’ wages. The government alleged that the defendant, Sreedhar Potarazu, an ophthalmic surgeon licensed in Maryland and
With Tax Day Nearly Behind Us, Justice Department Pivots to Warnings About Employment Tax Violations
Following a relentless flurry of press releases announcing criminal charges against tax evaders in the run up to today’s tax filing deadline (see here, here, and here), the Justice Department wasted no time in turning its attention to its next target: employers and individuals who violate the federal employment tax laws. In
On the Eve of Tax Day, Justice Department Warns That Tax Evaders Will Face Prison Time
With only four days remaining until “Tax Day,” the Justice Department’s well-publicized campaign to deter potential tax evaders continues with more stern warnings to taxpayers. In a bleak press release entitled “With the Individual Income Tax Filing Deadline Approaching, Justice Department Warns Willful Violations of Tax Laws Are Criminal,” the Justice Department sounds the warning