A recent decision of the United States Court of Appeals, Federal Circuit holds that the pre-2004 regulation limiting willful FBAR penalties to a maximum of $100,000 is notapplicable. As many tax practitioners know, 31 U.S.C. § 5314(a) requires taxpayers who have accounts with foreign financial institutions, specifically any person with a financial interest in or signature authority over foreign financial …
Section 7206 establishes, among other crimes, the federal tax crime of making false or fraudulent statements to the IRS, and aiding or assisting a taxpayer in making such statements. This post focuses on the crime of aiding or assisting the preparation of a false or fraudulent document that is presented to the IRS. The relevant statute provides as …
Section 7206 establishes, among other crimes, the federal tax crime of making false or fraudulent statements to the IRS, and aiding or assisting a taxpayer in making such statements. Common violations of section 7206 include falsely inflating deductions or underreporting income. However, unlike a number of other federal tax crimes, section 7206 does not technically require that the government prove …
Section 7203 of the Internal Revenue Code creates the federal crime of willfully failing to (1) file a tax return, (2) supply information, or (3) pay a tax. The Department of Justice’s position is that this misdemeanor offense of willfully failing to file a tax return, pay tax, keep records or supply information should only be charged when a defendant …
Internal Revenue Code section 7212(a) creates two separate offenses: (A) Corrupt or forcible interference, and (B) corrupt endeavors to impede. The relevant statute provides as follows: I.R.C. § 7212 – ATTEMPTS TO INTERFERE WITH ADMINISTRATION OF INTERNAL REVENUE LAWS (a) Corrupt or Forcible Interference.–Whoever corruptly or by force or threats of force (including any threatening letter or communication) …
