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Court Holds That Probable Cause is Necessary for Extradition in Tax Case

In the extradition of Massimiliano Lanzani, 2010 U.S. Dist Lexis 14044 (C.D. Cal.  2010)

     Spain sought to extradite Mr. Lanzani for tax fraud.  The request was made under 18 U.S.C. Section 3184.  Spain has a value added tax system.

     The Court found that Spain had to establish probable cause that the defendant had violated the law.  The documents presented by Spain failed to establish probable cause. As a result, Spain's request was denied without prejudice.

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