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Category Archives: Criminal Tax

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IRS Telephone Fraud By “Mr. F-#-@-K Y-O-U”

Posted in Criminal Tax
Every year the IRS sends out its “Dirty Dozen” list.  This is a compilation of the most prevalent tax scams, with the intent to inform and warn taxpayers of tax related rip-offs. The very first on the list involves phone scams.  The IRS warning reads as follows: Phone Scams: Aggressive and threatening phone calls by… Continue Reading

Is the Internal Revenue Service Lying?

Posted in Criminal Tax
Do you remember the controversy where the IRS was accused of targeting and unfairly auditing the Tea Party? In an article Sunday from CNN’s Political Ticker by Sara Fischer, the IRS has claimed that it is unable to recover subpoenaed emails from former IRS official Lois Lerner. The reason given is a “computer crash.” A firestorm has erupted in… Continue Reading

First Lady of Tax Fraud

Posted in Criminal Tax
The IRS just issued its Criminal Investigation Annual Report.  Budget constraints caused the staffing of Special Agents to drop to the lowest numbers in recent history, but 2013 included a 12.5 percent increase in investigations initiated and a nearly 18 percent gain in prosecution recommendations. Specifically, CI initiated 5,314 cases and recommended 4,364 cases for… Continue Reading

Gentleman’s Club Owner Hit With Fraud Penalty

Posted in Criminal Tax
A new Tax Court decision just came out – Potter v. Commissioner, TC Memo 2014-18.  The case involved a “gentleman’s club” owner in Michigan. In December 2006 IRS special agents engaged in an undercover investigation of Potter’s Pub, posing as buyers interested in acquiring the business. John Potter assured the agents that Potter’s Pub was… Continue Reading

Breaking Bad and Tax Planning?

Posted in Criminal Tax, Tax Planning
In last Sunday’s final episode of “Breaking Bad”, Walter White broke into his former business partner’s house (Elliot and wife Gretchen). Reason?  To give them close to 10 million dollars in cash so they would set up a trust for Walter’s son.   Walter had been looking for ways to get the cash to his… Continue Reading

Part Two – Could “Johnny Football” Go To Jail?

Posted in Criminal Tax
“Johnny Football” Manziel had an amazing game against Alabama this past weekend.  There is no doubt he is one of the greatest ever to play college football. Many famous athletes like Manziel have “entourages.”  The Urban Dictionary has many definitions of what an entourage is – but it is basically a “posse” that follows the… Continue Reading

Could Johnny Football Go To Jail?

Posted in Criminal Tax
ESPN reported in August that Heisman Trophy winner Johnny Manziel “…agreed to sign memorabilia in exchange for a five-figure flat fee during his trip to Miami for the Discover BCS National Championship.” Of course the real fear for Texas A&M faithful was that he would lose his eligibility to play football for violating NCAA Bylaw… Continue Reading

“Breaking Bad” and Tax Evasion

Posted in Criminal Tax
I love the TV Series “Breaking Bad” on AMC.  In a nutshell, it is about a tough luck high school chemistry teacher named Walter White who turns into a major drug dealer and murderer. This clip sets it up nicely. Several episodes involve a cover-up of tax evasion.  After her baby is born, Walter’s wife,… Continue Reading

IRS Announces Information Sharing Agreement with Australia and the UK to Combat Tax Evasion

Posted in Criminal Tax, Tax Planning
The IRS continues to aggressively pursue offshore tax evasion.  Another example of which is plan to share tax information with Australia and the United Kingdom.  The announcement says that the target is trusts and companies holding assets on behalf of residents throughout the world. Popular countries used to create of trusts and other entities according to… Continue Reading

New IRS Offshore Voluntary Disclosure Forms

Posted in Criminal Tax
In past offshore voluntary disclosures initiatives under the famed OVDI program – the IRS has continually adjusted the information it seeks from Taxpayers. The IRS has just come out with formal IRS Forms to take the place of the Word documents used before.  The new forms are: Form 14457 – Offshore Voluntary Disclosure Letter Form… Continue Reading

US and Switzerland sign agreement to combat tax evasion.

Posted in Criminal Tax
The IRS has been clear that it is very serious about US taxpayers with foreign financial assets being compliant with tax reporting requirements.  There have been three rounds of the Offshore Voluntary Disclosure Initiative.  It is not too late to enter into the program. Anyone with an undisclosed foreign account should seriously consider entering the… Continue Reading

How do the Federal Sentencing Guidelines work?

Posted in Criminal Tax
If you ever wondered how the Federal Sentencing Guidelines work – here is an outline of the basics: First Step – Determine Which Guidelines Manual Applies: The Sentencing Guidelines require that courts use the Guidelines Manual in effect on the date of sentencing.  If the court determines that the use of the Guidelines Manual would… Continue Reading

Hiding Assets in Foreign Countries? Not a good idea

Posted in Criminal Tax
The IRS’ interest in cracking down on offshore tax havens is well documented.  Just this week, the Department of justice announced that the oldest bank in Switzerland – Wegelin & Co. plead guilty to conspiring with U.S. taxpayers and others to hide more than $1.2 billion in secret Swiss bank accounts and the income generated in… Continue Reading

IRS Abuse and the Tweel Doctrine

Posted in Criminal Tax
It is a well established principal of law that it is a violation of a person’s 4th Amendment rights if a consent search is induced by deceit, trickery or misrepresentation by the IRS. Courts will suppress evidence obtained by deceit, trickery or misrepresentation. The Tweel Doctrine is named after a famous 5th Circuit case.   The basics of the case… Continue Reading