Taxpayer was convicted of conspiracy to defraud the United States by counseling taxpayers how to claim false expenses.
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Frank Gangi resided in the U.S. Virgin Islands. The IRS issued summons to investigate whether Gangi was required to pay income taxes. Taxpayer moved to quash the summons. The motion was denied.
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.
Taxpayers operated a day school primarily on a cash basis: requesting at least some parents to pay tuition in cash, paying teacher salaries in cash, refusing to issue tax forms reflecting income paid to teachers, and, in some cases, encouraging teachers not to file tax returns or report income they earned from the school.
Enhancement for criminally derived income was not applicable to tax returns that did not fail to identify income but overstated expenses.
Taxpayer appealed his conviction for failing to file a tax return based upon the testimony of an IRS agent who read an IRS transcript purporting to reflect a history of taxpayer's tax return history. Taxpayer asserted that his confrontation clause rights had been violated since the IRS agent did not input the information that resulted in the transcript.
Plea Agreement Appellate Waiver Did Not Apply and Sentencing in Accordance with 2009 Guidelines Violated Taxpayer's Rights Under Ex Post Facto Clasue.
Taxpayer filed a petition challenging Respondent Commissioner of the Internal Revenue Service's (IRS) notices of deficiency. Lawrence argued that his pension and social security benefits did not constitute taxable income because they were paid directly to the IRS pursuant to an IRS levy to recover his outstanding income taxes. The United States Tax Court upheld the Commissioner's deficiency determination. Lawrence appealed.
The Internal Revenue Service conceded a $638,798 tax deficiency it had assessed against a Tampa business executive Alfred Schaer. The tax deficiency arose from a dispute over the date Schaer completed the purchase of the stock of Tampa-based Computer Management Consultants, Inc. in March 2005. Taxpayer made an invalid S election and as a result did not owe additional taxes.
Indictment Charging Tax Evasion Was Not Barred By the Statute of Limitations Even though the Tax Return Had Been Filed More Than Six Years Earlier Because the Taxpayer Provided Bogus Documents to the IRS Subsequent to the Filing of the Tax Return to Conceal the Fraud.