It has been long recognized that a criminal statute that is ambiguous and capable of being interpreted to apply to more than one set of conduct, should be applied in a fashion that is narrower in scope.
Archives June 2017
Does a Green Card Holder Have to File U.S. Income Tax Returns and FBARs
Written by on in Criminal Tax Cases.
A citizen of the United Kingdom held a green card in the United States. He was indicted for not filing U.S. income tax returns and FBARs. The taxpayer challenged the constitutionality of the indictment.
Which Sentencing Guidelines Should be Used to a Section 7212?
Written by on in Tax Audits, Appeals & Litigation.
Which Federal Sentencing Guidelines Apply to a Section 7212 Violation of the Internal Revenue Code for Obstruction of Justice?
