This post breaks down the elements of tax evasion of payment and assessment under 26 U.S.C. § 7201 of the Internal Revenue Code.
This post reviews the elements of tax fraud with a focus on filing a false return in violation of 26 U.S.C. § 7206.
This post continues are review of the DOJ Criminal Tax Manual with a focus on witness immunity and the hierarcy within DOJ Tax enforcement.
This post continues our review of DOJ’s Criminal Tax Manual providing insights into adminstrative and grand jury investigations.
This is the first post in a series that reviews the DOJ Criminal Tax Manual and highlights relevant sections for taxpayers and practitioners.
This post lays out the common fee structures in criminal tax cases to allow taxpayers to analyze the potential costs for litigation