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Court Finds That the Criminal Offense for a U.S. Resident’s Willful Failure to File an FBAR was Not Unconstitutionally Vague

Court Finds That the Criminal Offense for a U.S. Resident’s Willful Failure to File an FBAR was Not Unconstitutionally Vague

Certain taxpayers who are citizens of foreign countries also have green cards granting them resident status in the United States. Some argue the laws regarding their obligation to file FBARs are unconstitutionally vague.

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What is The Weapon of Choice of the Government When Prosecuting Taxpayers?

What is The Weapon of Choice of the Government When Prosecuting Taxpayers?

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.

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Prosecutor Misconduct was Not Sufficient to Reverse Tax Conviction U.S. v. Guinn, 2012 U.S. App. LEXIS 5103 (11th Cir. 2012)

Taxpayer was convicted pursuant to 7203 for failing to file several tax returns. Taxpayer appeal based upon the alleged misconduct of the prosecutor. The Court affirmed based upon "harmless error".

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