Tax Crimes

Update: As of November 21, 2019, various news sources are reporting that Former Mayor Pugh has pleaded guilty to four of the 11 charges in an executed plea deal. According to these reports, she pleaded guilty to at least one charge of tax evasion. Earlier this year, we reported the first public display of federal […]

Cryptocurrency start-up firms sometimes attempt to raise funding for an original cryptocurrency venture through Initial Coin Offerings (ICOs). Typically, the firm presents a whitepaper plan detailing the: (1) project requiring funding, (2) amount of funding needed, (3) amount of cryptocurrency that investors will retain, (4) specific currency accepted, and (5) timeline for the ICO campaign. […]

On May 10, 2018, the United States Attorney for the District of Maryland announced that new Baltimore Police Commissioner Daryl De Sousa has been charged with three misdemeanor counts of willful failure to file a U.S. individual income tax return. Specifically, the charges allege that Commissioner De Sousa failed to file returns for tax years […]

A recent decision has shaken tax authorities in the US–Bedrosian v. United States, No. 2:15-cv-05853 (E.D. Pa. Sept. 20, 2017). Case History The case was filed by the plaintiff, Arthur Bedrosian, to obtain a refund of the $9,757.89 that he paid to the Internal Revenue Service (IRS). This amount was paid for his alleged willful […]

On March 23, 2018, the IRS issued IR-2018-71, reminding taxpayers that they must report income from virtual currency transactions on their income tax returns. The IRS defined virtual currency as “a digital representation of value that functions in the same manner as a country’s traditional currency.” The IRS emphasized that, as with any other property […]

Glen Frost, Managing Partner The Comptroller’s Field Enforcement Division and the Criminal Investigations Division of the Maryland Attorney General’s Office, working in tandem, investigated and prosecuted two more Maryland tax preparers—resulting in guilty pleas. On July 24, 2018, Maryland Attorney General Brian E. Frosh and Comptroller Peter Franchot announced that two tax preparers operating in […]

Eli Noff, Esq.,Partner On August 26, 2019 the United States Department of Justice (DOJ) issued a press release reporting that a federal grand jury returned a superseding indictment charging Taxpayer with: (1) failing to file Reports of Foreign Bank and Financial Accounts (FBARs); (2) filing false individual income tax returns with the Internal Revenue Service […]

Eli Noff, Esq., Partner Taxpayers must use FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR) to report their foreign accounts if the aggregate value of the accounts exceeds $10,000 anytime during the calendar year.[1] Before 2004, non—willful FBAR violators were not subject to a penalty. However, for non—willful violations on or after […]

Eli Noff, Esq., Partner On October 28, 2019, in U.S. Auto Sales, Inc. v. Commissioner,1 the Tax Court dismissed a case, holding that the Notice of Deficiency (NOD), issued by the Internal Revenue Service (IRS), was ambiguous on its face because it identified two different taxpayers as potentially liable for the deficiencies. The decision should […]

Eli Noff, Esq., Partner On November 19, 2019, in Sullivan v. Commissioner,[1] the Tax Court held that the IRS settlement officer (SO) did not abuse discretion in sustaining levies for Harvard law professor (Taxpayer) who had not filed tax returns from 2005-2013, and who subsequently neglected to provide the IRS with any financial documents. Taxpayers […]