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Recent Posts by Ronald Marini

Whistleblower Case Hinges on IRS Time Frame for Setting Awards

The U.S. Tax Court has given the IRS until Sept. 24 to respond to an amicus brief in support of what could amount to an award of tens of millions of dollars for whistleblower Joseph Insinga, an informant who implicated seven major corporations in tax evasion in 2007 (Insinga v. Comr., Tax Court Order No.…
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Sentencing—Apprendi Applies to Criminal Fines

The Supreme Court has extended the rule in Apprendi  v. New Jersey, 530 U.S. 466 (2000). Apprendi held that the Sixth Amendment reserves to juries the determination of any fact, other than the fact of a prior conviction, that increases a criminal defendant's maximum potential sentence. In Southern Union Co. v. United States, 132 S.…
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Swiss Banks Giving Up Employees to IRS

Looking for leniency in tax evasion investigation, banks surrender data Thousands of employees of Swiss banks are finding that their employers are hanging them out to dry in exchange for hoped-for leniency in connection with American accounts involved in a tax evasion investigation. Bloomberg reported Thursday that several Swiss banks so far have turned over…
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