Generally, the Federal Sentencing Guidelines are based upon tax loss. The definition normally does not include interest and penalties. However, when a taxpayer is convicted of a tax offense in which he attempted to evade payment of the tax, interest and penalties, the Court may include interest and penalties in its calculation of tax loss.
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Recent entries
Understanding the X-Date: How the IRS Funding Increase Helps Forecast the Nation's Financial Position
Understanding AI-generated Tax Scams: A Letter to the IRS
The inflation reduction act of 2022 provies the IRS with $79 billion to focus on enforcement and operations
Unfair Double Counting For Tax Loss When Determining Federal Sentencing Guidelines
Court Finds That the Criminal Offense for a U.S. Resident’s Willful Failure to File an FBAR was Not Unconstitutionally Vague