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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

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

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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Movie Star Wesley Snipes Convicted on Three Tax Counts U.S. v. SNIPES, LEXIS 123180 (N.D. FL 2010)

Federal Sentencing Guidelines Treat Felony and Misdemeanor Tax Violations the Same. The Result Can Lead to Misdemeanor Sentences Being Ordered Served Consecutively.

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