The Government Has Focused a Considerable Amount of Energy To Prosecute Taxpayers Who Failed to File FBAR Reports and Accurately Account For Taxes. The Government has used the Required Records Doctrine to compel taxpayers to produce foreign bank account records.
Tag archives: 7202
The Required Records Doctrine is the Weapon of Choice of the Government When Prosecuting Taxpayers For Failure to File FBAR Reports and Account For Taxes
Understanding the Purpose of the Criminal Investigation Division of the Internal Revenue Service and Its Effect on Criminal Investigations and Indictments
Written by on in Tax Fraud Report.
Taxpayers who are the target of an Internal Revenue Service Criminal Investigation Division investigation benefit from an understanding of the purpose of these investigations.
Court Holds That in Certain Criminal Tax Cases the Date that the Statute of Limitations Begins to Run is the Date that the Taxpayer Acts Willfully
Written by on in Tax Fraud Report.
The statute of limitations for tax crimes may not begin to run on the later of the date the tax return was due or the date the return was filed. With regard to certain tax crimes, such as 7202, the date that the statute of limitation begins is the date that the taxpayer acted willfully. This will often be a question of fact that must be decided by the jury. As a result, a motion to dismiss based upon dates set forth in the indictment may be denied.
Taxpayer convicted of conspiracy to iimpede IRS with 1099 scheme. U. S. v. SCHROEDER, U.S. App. LEXIS 19393 (6th Cir. 2012)
Written by on in Tax Fraud Report.
Court found that there was ample evidence that taxpayer conspired to impede the IRS by concealing income by using a non-profit entity and mishandling 1099 forms.