Tax deficiencies are at the center of all criminal tax cases. This article looks at the different methods used by the IRS to calculate a tax filer’s income and the resulting deficiency in tax revenue.
Criminal tax evasion is defined by the Supreme Court in the seminal case Spies v. United States. This post looks at the increased burden on the government when they try to turn a failure to file into a prosecution for tax evasion.
This post reviews the IRS whistleblower statute which provides awards for informants who provide information on tax fraud and underpayment of taxes.
The United States Sentencing Commission is responsible for compiling sentencing statistics for certain federal crimes. This post reviews this report for criminal tax cases in 2017.
The criminal tax loss takes center stage in any federal tax sentencing. This post goes through the ways tax losses are calculated in federal court, and the need for a tax loss calculation in any criminal tax defense.
The guideline range is the starting point for sentencing a criminal defendant. However, there are multiple avenues at a defense attorneys disposal to argue for a sentence below the recommended range. This article examines the commonly used tactics to get the least severe sentence for a federal client.