This post reviews the IRS guidance for crypto specific transactions such as mining, staking rewards, hard forks and air drops.
This post reviews various IRS publications which detail how a taxpayer should treat cyrpto investments on their yearly returns.
This post reviews the statute of limitations in the Internal Revenue Code and outlines issues under the tax fraud and evasion statutes.
This post uses the Supreme Court’s decision in Boulware to outline the role of the IRC in determining a tax deficiency under the tax evasion statute.
This post looks into the procedural and practical requirements to effectively expand the appelalte record through a motion for new trial.
The Fifth Amendment to the United States Constitution holds various protections for criminal defendants. One of the more well-known clauses is the Double Jeopardy Clause – “no person shall be subject for the same offense to be twice put in jeopardy of life or limb.” On its face, this clause protects a criminal defendant from […]
This post analyzes how the Fifth Amendment right against self-incrimination applies to the production of documents in criminal tax litigation.
This post looks at the promulgation of rules in the Medicare program and the types of claims targeted by federal investigative agencies.