Author archives: david

Tax Return Preparer Found Guilty of Preparing False Returns and Government Was Permitted to Call Witnesses Not Charged in the Indictment Who Defendant Prepared False Returns For.

Defendant, a Tax Attorney, Was Convicted of Suggesting and Carrying out a Scheme to Assist Taxpayers in Avoiding Payment of the Full Amount of Taxes Due on a Litigation Settlement. Eventual Payment of Tax by Taxpayers Did Not Exonerate the Defendant

Hotel Owners and Businessmen Sentenced to 10 Years for Tax Offenses in South Florida.

There were 2,814 taxpayers convicted in 2010 of tax violations.

Federal Sentencing Guidelines Treat Felony and Misdemeanor Tax Violations the Same. The Result Can Lead to Misdemeanor Sentences Being Ordered Served Consecutively.

In Case Where Taxpayer Was Charged with Filing False Tax Returns for Clients that Overstated Expenses, Testimony of Former Clients Not Contained in the Indictment Was Permitted as 404(b) Evidence to Show Wilful Intent and There Was No Violation of the Confrontation Clause

Defendant Charged With Tax Evasion Waived a Valid Venue Argument by Failing to Make a Timely Motion.

Taxpayer charged with structuring and filing a false tax return was ordered to pay $3,500,000 restitution for funds embezzled from charities he had created although the specific charges did not establish the loss.

Taxpayer's Use of Legal Deferred Compensation Plan Supported an Indictment for Criminal Tax Fraud

There is No Requirement That The Government Prove a Taxpayer Had Funds to Pay Tax to Obtain a Conviction Pursuant to Section 7202. Further, the Statute of Limitations for an Offense Under Section7202 is Six Years.