Tag archives: 7203

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.

The Fifth Amendment protects individual taxpayers from being compelled to testify when such testimony is incriminating. This rule has been held to apply to the records in the custody and control of the taxpayer. However, when the taxpayer is required to maintain the records for non-law enforcement reasons that are public in nature, the Required Records Doctrine authorizes the government to subpoena such records. This is recognized as an exception to the Fifth Amendment.

Taxpayers who find that they are the target of an IRS tax investigation for possible criminal tax violations are presented with difficult choices that often affect the ultimate outcomes of their cases.

Taxpayers who are the target of an Internal Revenue Service Criminal Investigation Division investigation benefit from an understanding of the purpose of these investigations.

Two Kentucky men were sentenced to between five and more than six years in prison today after pleading guilty in April and May to conspiring to defraud the United States, wire fraud, and aggravated identity theft.

An Austell, Georgia, couple was sentenced to prison for their role in a stolen identity tax refund fraud scheme.

A Cranston, Rhode Island, resident pleaded guilty yesterday to aiding and assisting in the preparation of false tax returns, wire fraud, theft of government funds and aggravated identity theft.

Taxpayer made large profits selling guns. At trial he was acquitted of all felony charges. However, he was convicted of two misdemeanor tax charges pursuant to 26 USC 7203. The taxpayer appeal because the court did not permit the defendant's expert to testify as to the taxpayer's intent because it was the ultimate issue for the jury to decide. Taxpayer's counsel failed to properly rephrase the questions to get past the government's objection.

IRS used Net Worth Method to obtain tax evasion and false employee tax returns against a nightclub owner. The Court provided a detailed analysis of Rule 29.

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.