Daily Compliance News: May 7, 2025 the Private Lives Edition
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC
The Presumption of Innocence Podcast: Episode 4 - Understanding the Employee Retention Credit
The Presumption of Innocence Podcast: Episode 2 - Avoid Falling Prey: The Dirty Dozen and Other Trending Tax Scams
Argentina: A Look at the Case of Lázaro Báez - Laundering the Proceeds of Corruption and Tax Fraud
Podcast: Cum-Ex Dividend Trade Investigations
Spinning the Globe: When the Music Stops, the IRS Listens - Imagine standing on stage in Ibiza, Tokyo, or Miami, spinning beats to millions while pulling in seven figures per gig. That’s the reality for Dutch DJs Tiësto...more
On September 12, 2024, the U.S. Department of Justice (“DOJ”) announced that Frank Richard Ahlgren III pleaded guilty to filing a false tax return underreporting gains from selling $3.7 million in Bitcoin. As we discussed...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
In this episode, we are joined by Special Agent Jonathan Schnatz, Senior Analyst with IRS Criminal Investigation. Special Agent Schnatz will discuss his work with an international law enforcement and tax compliance group, and...more
While not as well-known as the Paycheck Protection Program, the Employee Retention Credit (“ERC”) program was another form of Covid relief provided by the federal government to businesses in 2020 and 2021. The ERC program...more
For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims. More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC...more
New York Governor Kathy Hochul recently signed into law new legislation expanding the reach of the New York False Claims Act (NYFCA) to entities that fail to file tax returns in New York. Unlike the federal False Claims Act...more
Taxpayers routinely ask me if they can go to jail for not paying their federal income taxes. Admittedly, the bar is not that high for felony tax evasion—the government must only prove three elements: (i) willfulness; (ii)...more
Tax Litigation: The Week of April 25th, 2022, through April 29th, 2022 Sestak v. Comm’r, TC Memo. 2022-41| April 25, 2022 | Weiler, J. | Dkt. No. 17285-18...more
In Chico v. Commissioner, the taxpayers challenged the Tax Court’s assessment of a fraud penalty. The Tax Court had imposed civil fraud penalties against the married taxpayers, finding clear-and-convincing evidence of fraud...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 16 – August 20, 2021 - Catlett v. Comm’r, No....more
It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more
Male Escort Gets 21 Months In Prison For Tax Case - He lied on his tax returns, resulting in a tax loss to the IRS of $278,325. A male escort who lied to the IRS about his income was sentenced to 21 months in prison and...more
Federal tax penalties have always been an IRS priority. But, perhaps more so today than three decades ago. For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion. Compare that...more
The Internal Revenue Service has revived Form 1099-NEC to eliminate confusion about complying with new filing deadlines aimed at combatting fraud. ...more
The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more