Social Media Ideas for Criminal Tax Law

When filing overdue tax returns requires criminal defense, not just an accountant

If the non-filing was innocent, the strategy may be civil. If it was willful, the strategy may need to begin with criminal tax counsel before any return is filed.

Section 277: When a False Tax Statement Becomes a Criminal Offence

Section 277: When a False Tax Statement Becomes a Criminal Offence False verification, mens rea, prosecution, compounding – and the major change under Section 482 of the Income-tax...

Professional Sophistication and the Civil Fraud Penalty: How an IRS Auditor’s Own Expertise Sealed His Fate in Tax Court

Peter J. Janangelo, Jr. and Mary Ann Janangelo v. Commissioner of Internal Revenue, T.C. Summary Opinion 2026-8 (Tax Ct. Aug. 27, 2026) Tax professionals are often held to a h...

DOJ’s Fraud Division Memo Puts Tax Enforcement Front and Center: What Companies Across Industries Need to Know

Trust Fund Recovery Penalty Willfulness and the Capping Effect of Corporate Offers-in-Compromise: A Technical Analysis o...

Amodio v. Commissioner, T.C. Memo. 2026-96, Docket No. 9959-22L (Sept. 28, 2026) For tax controversy practitioners, Certified Public Accountants, and Enrolled Agents, naviga...

Tax Administration, Sham Partnerships, and Voluntary Compliance: Understanding the Eleventh Circuit’s Affirmation of the...

Filipowski v. Commissioner, No. 25-11382 (11th Cir. 2025), September 2, 2026 For tax professionals representing clients with significant tax delinquencies, the Offer-in-Comp...

Tax Fraud Blotter: Keep on truckin'

Special Tax Shelter Strategy; ghost prepared; material falsehoods; and other highlights of recent tax cases.

Tax Fraud Blotter: Open to interpretation

Fugitive from justice; private school tuition; without clients' knowledge; and other highlights of recent tax cases.

FBAR Willfulness, Recklessness, and the Excessive Fines Defense: Key Insights for Tax Professionals from United States v...

United States v. Rund, No. 24-1958, ___ F.4th ___ (4th Cir. Sep. 4, 2026), affirming 743 F. Supp. 3d 779 (E.D. Va. 2024) As tax professionals representing clients with interna...

The Full Payment Requirement and the Presumption of Correctness: Jurisdictional Lessons from Pellegrino v. United States

Pellegrino v. United States, No. 1:26-cv-00403, 2026 WL (Fed. Cl. Aug. 20, 2026) In Pellegrino v. United States, No. 1:26-cv-00403 (Fed. Cl. Aug. 20, 2026), Judge Philip S....

Tax Fraud Blotter: Fairway to heaven

Fibbing for a 68-foot yacht; four bedroom in Beverly Hills; and other highlights of recent tax cases.

Full Abatement of Penalties and Surcharges for Outstanding Tax Liabilities Continues in 2027

Tax Fraud Blotter: Crook from Crookston

Toxic pollutants; fabricated gambling winnings and losses; financial shortfalls; and other highlights of recent tax cases.

Tax Fraud Blotter: Friends in high places

Bold and arrogant; secure repeat business; questionable tax returns; and other highlights of recent tax cases.

Foreign Tax Credits Against the Net Investment Income Tax: A Critical Analysis of the Federal Circuit’s Decisive Rulings...

Estate of Paul Bruyea v. United States, F.4th , No. 25-1563, ECF No. 58 (Fed. Cir. Aug. 31, 2026), reversing Bruyea v. United States, 174 Fed. Cl. 238 (2024). Matthew Christ...

The Burden of Proof in Certified Mailing: Analyzing Wales v. Commissioner and Jurisdictional Thresholds

Wales v. Commissioner, T.C. Memo. 2026-82, (Sept. 3, 2026) In the practice of tax controversy, few issues are as critical as the precise boundaries of the United States Tax Co...

Not guilty is not a tax victory

The jury said not guilty. The next envelope was still a 75 percent IRS fraud penalty. More from JD Supra: https://www.jdsupra.com/legalnews/not-guilty-is-not-a-tax-victory-8829588/...

NYS Issues Invalid Tax Notice So Responsible Person Is Not Liable for Sales Tax

Tax Practice Alert: Alteration of the Perjury Jurat Invalidates Refund Claims Under IRC Section 7422

Darrin Johnson, Jr. v. Internal Revenue Service, No. 1:25-cv-02117 (D. Md. Sept. 11, 2026) For tax professionals advising clients on tax controversy and refund claims, maint...

Gross Income Realization vs. Nontaxable Receipts: Tax Court Evaluates Unrestricted Art Deal Funds in Tunkl v. Commission...

Tunkl v. Commissioner, T.C. Memo. 2026-83 (Sept. 10, 2026) For federal income tax professionals advising high-net-worth clients, dealers, and corporate entities engaged in inf...

The IRA Compliance Resolution System: A Technical Analysis of Revenue Procedure 2026-33 and the New Voluntary Correction...

Rev. Proc. 2026-33, October 22, 2026 The Internal Revenue Service has issued Revenue Procedure 2026-33, establishing the IRA Compliance Resolution System (ICRS). Effective May...

Tax Treatment of ETF Security Transfers: An Analysis of Revenue Ruling 2026-20 and Notice 2026-62

Rev. Rul. 2026-20, 2026-20 I.R.B. 1, September 28, 2026 Notice 2026-62, 2026-20 I.R.B. 1, September 28, 2026 In a coordinated regulatory release, the Department of the Treasu...

Tax Fraud Blotter: Jet skis, dirt bikes and trailers, oh my!  

"Godfather" sculptures; designer handbags; nonprofit embezzlement; and other highlights of recent tax cases.

Tax Court Upholds Steep Penalties on Charity Insiders Who Diverted Funds