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Tax Court Tax Fraud Internal Revenue Service

Polsinelli

Tax Court Strikes out Smoltz and Klesko’s Big K SCE, but Provides Relief for Those Facing Fraud Allegations

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In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

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Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Lerch, Early & Brewer

Tenth Circuit Affirms Deficiencies, Penalties for Offshore Income

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Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more

Foodman CPAs & Advisors

El IRS Advierte A Los Contribuyentes Contra Las Estrategias De Evasión Fiscal

El IRS concluyó su lista de Estafas de la Docena Sucia (“Dirty Dozen”) del 2022 recomendando a los contribuyentes a estar atentos y evitar ser engañados por las estrategias de evasión fiscal....more

Freeman Law

Tax Court in Brief | Sestak v. Commissioner | Badges of Fraud, Bribery, and Violation of Sharply Defined Public Policy

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Tax Litigation:  The Week of April 25th, 2022, through April 29th, 2022 Sestak v. Comm’r, TC Memo. 2022-41| April 25, 2022 | Weiler, J. | Dkt. No. 17285-18...more

Freeman Law

Fraud Penalty Affirmed: In Not-So-Chic Fashion, the Ninth Circuit Upholds Fraud Penalties in Chico

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In Chico v. Commissioner, the taxpayers challenged the Tax Court’s assessment of a fraud penalty. The Tax Court had imposed civil fraud penalties against the married taxpayers, finding clear-and-convincing evidence of fraud...more

Freeman Law

The Tax Court in Brief - August 2021 #4

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 16 – August 20, 2021 - Catlett v. Comm’r, No....more

Fox Rothschild LLP

Tax Court Holds Commissioner Failed To Comply With Supervisor Approval Requirement For Fraud Penalty

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In Graev III, issued late last year, the Tax Court held that the Commissioner must comply with section 6751(b)(1) as part of his burden of production for tax penalties. Section 6751(b)(1) requires that an initial penalty...more

Foster Garvey PC

The Complete Saga of Former U.S. Tax Court Judge Diane L. Kroupa is Now Finally Concluded

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As reported in my April 7, 2016, October 3, 2016 and October 27, 2016 blog posts, former U.S. Tax Court Judge Diane L. Kroupa and her then husband, Robert E. Fackler, were indicted on charges of tax fraud. Specifically, they...more

Coblentz Patch Duffy & Bass

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

Foster Garvey PC

Former Tax Court Judge Kroupa Is Back in the News

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As reported in my April 2016 blog post, former U.S. Tax Court judge Diane Kroupa and her husband, Robert E. Fackler, were indicted on charges of conspiracy to defraud the United States, tax evasion, making and subscribing a...more

McDermott Will & Emery

Whose Intent to Evade Tax Is It?

On July 29, 2015, the Federal Circuit, rejecting the Tax Court’s decision in Allen v. Commissioner, 128 T.C. 37 (2007), held in BASR Partnership v. United States, No. 2014-5037, that section 6501(c)’s suspension of the...more

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