eBook | Foreign Asset Reporting: Navigating the Choppy Financial Seas.

Eggshell Audits: Don’t Get Cracked

In this episode I discuss eggshell audits and what to do when it comes to filing returns for tax periods subsequent to periods under examination.

The Changing State of Voluntary Disclosure

A new year brings with it many things, including, of course, news and updates from the IRS. As tax year 2019 draws closer, it’s time to start thinking about the many changes to come, like the IRS’ recently published updates to the 2018 OVDP and Voluntary Disclosure rules. As with most situations regarding the IRS, nothing stays […]

Criminal Tax Liabilities & Sentencing Part III: The Pre-sentence Investigation Report

In this podcast, I discuss the pre-sentence investigation report. Below is a quick and dirty outline: After conviction and prior to sentencing, a probation officer will interview the def. and prepare a PSR. In the PSR, the probation officer will: Calculate the defendant’s offense level and criminal history category, State the resulting sentencing range and […]

HOW THE IRS RECONSTRUCTS INCOME IN TAX FRAUD CASES – A WEBINAR

This is a webinar that I presented in partnership with CPA Academy. I’m honored to lecture for such a fine CPE provider. For those who are interested in obtaining CPE credit, click here to sign up. Below is more information about the program: Course Description In one of the climactic scenes from 1954’s On The […]

Demystifying the FBAR – A Webinar

This is a webinar that I presented in partnership with CPA Academy. I’m honored to lecture for such a fine CPE provider. For those who are interested in obtaining CPE credit, click here to sign up. Below is more information about the program: Course Description This course breaks the FBAR down into its individual components and […]

Criminal Tax Liabilities & Sentencing: Part I

This is the first of several parts. There is a lot of information to discuss that it might feel like drinking water out of a fire hydrant. Sentencing issues are arguably the most important part of a federal criminal tax case. Because the likelihood of conviction is so high, the best that defense counsel can do […]