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Monthly Archives: November 2017

Will Marinello Be The McDonnell Of Tax Crimes?

According to Law360, Carlo Marinello will argue to the U.S. Supreme Court next month that a vague tax law gives prosecutors power to criminalize anything that makes the IRS' job harder, in a case that could see the high court continue limiting broad criminal laws as it did last year in U.S. v. McDonnell. Marinello was…
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Partner-Level CDP Case Can Be Revied by the Tax Court

The Tax Court in McNeill, 148 TC No. 23 (2017), held that it has jurisdiction under Section 6330(d)(1) to review a notice of determination when the underlying tax liability consists of a penalty relating to an adjustment to a partnership item excluded from deficiency procedures by Section 6230(a)(2)(A)(i). The taxpayer was a partner in a…
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No Motion To Dismiss For a Taxpayer With Hidden Foreign Bank Accounts

According to Law360 a Washington federal judge on October 6, 2017 declined to toss the U.S. government’s suit accusing a man of willfully failing to disclose foreign bank accounts, finding that the allegations could reasonably lead the court to infer that the man understood IRS reporting requirements. In denying Jeffrey P. Pomerantz’s motion to dismiss…
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