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Court of Appeals Rules 23-Day Notice Requirement for Third Party Summonses is Mandatory in Tenth Circuit

In Jewell v. U.S., Taxpayer Sam Jewell was the subject of an IRS investigation which resulted in third party summonses being issued to banks located in both the Eastern and Western Districts of Oklahoma.  Mr. Jewell challenged both summonses because the IRS failed to provide him with notice of the summonses at least 23 days … Continue Reading

IRS Report Announces Major Increase in Criminal Investigations for 2013

On February 24, 2014, IRS Criminal Investigation (“CI”) announced the release of its 2013 annual report, which reflected a significant increase in criminal investigations and prosecution recommendations in the past year.  According to the report, there was an increase of 12.5 percent in completed investigations and an increase of nearly 18 percent in prosecution recommendations … Continue Reading

OECD Publishes Standard for International Automatic Tax Information Exchange

On February 13, 2014, the OECD published a standard for the automatic exchange of tax information among governments, intended to help fight cross-border tax evasion. Under the standard, governments would collect information from their financial institutions and exchange that information automatically with other countries annually. “While closely following FATCA, it does deviate in a number … Continue Reading

U.S. Signs FATCA IGA with Italy

Tax Analysts’ Tax Notes Today reports that on January 10, 2014, the U.S. signed a FATCA IGA with Italy, which became the 13th country to sign such a deal with the U.S.  With the Italian IGA signed, Italian banks and financial institutions will report information about eligible U.S. customers’ offshore accounts to the Italian government, … Continue Reading

IRS Collecting More Revenue, Prosecuting More Criminal Cases

The IRS has released Fiscal Year 2013 Enforcement statistics.  In FY 2013, IRS Enforcement collected more revenue than FY 2012, with fewer employees and while examining fewer returns than in FY 2012.  Collection activities, such as levies, liens and seizures all dropped significantly.  However, criminal investigations and prosecutions have risen. The IRS statistics can be … Continue Reading

IRS Announces New Mandatory IDR Procedures

Tax Analysts Tax Notes reports that the IRS Large Business and International Division (LBI) released mandatory, stringent new procedures for enforcing information document requests (IDRs) and issuing summonses, minimizing examiners’ discretion even at the manager level. Under the new process effective January 2, if information requested in an IDR isn’t received by the IDR response … Continue Reading

American Pleads Guilty to Hiding Money in Israeli Bank Accounts

Tax Analysts Tax Notes is reporting that David Raminfard of Los Angeles pleaded guilty on November 4, 2013, in federal court to one count of conspiracy to defraud the United States (Klein conspiracy).  According to court documents, Raminfard, a U.S. citizen, maintained undeclared bank accounts at an international bank headquartered in Tel Aviv, Israel, identified in … Continue Reading

Nevada Businessman Sentenced to Nine Years in Prison

Multiple outlets are reporting that on October 15, 2013, William Reed, a Nevada businessman, was sentenced to nine years in federal prison after pleading guilty to conspiracy to defraud the United States, tax evasion, and aggravated identity theft.  Reed was listed as the corporate officer for more than 1,000 companies purportedly headquartered in a lone … Continue Reading

FinCEN Fines TD Bank for Failing to Report Nearly $1 Billion in Suspicious Transactions Related to Florida Ponzi Scheme

The Financial Crimes Enforcement Network (FinCEN) announced the assessment of a $37.5 million civil money penalty against TD Bank, N.A. for failure to file suspicious activity reports related to the massive Ponzi scheme orchestrated by Florida attorney Scott Rothstein. The Office of the Comptroller of the Currency also announced the assessment of a concurrent $37.5 … Continue Reading


The IRS has issued a list of frequently asked questions on a new online registration system for financial institutions that must register with the IRS to comply with Foreign Account Tax Compliance Act requirements.… Continue Reading

IRS Enforcement Revenue Drops for 2nd Year

Tax Analysts Tax Notes reports that the IRS in fiscal 2012 collected less in enforcement revenue for a second straight year, bringing in just $50.2 billion compared with $55.2 billion in fiscal 2011 and $57.6 billion in fiscal 2010 — a 13 percent drop in the same two years that the agency also lost 14 … Continue Reading

Colorado Accounting Department Head Sentenced to Federal Prison for Failing to Pay Over Employment Taxes

Bloomberg BNA reports that a Colorado woman who managed the accounting department of a garage door company she co-owns was sentenced to 28 months for failing to pay $4.67 million in employment taxes (United States v. Pettyjohn, D. Colo., No. 1:13-cr-00020, sentencing 9/11/13).  Beth Ann Pettyjohn, of Englewood, was sentenced Sept. 11 by Judge William … Continue Reading

Zurich’s Oldest Bank Seeks Settlement with Department of Justice

Bloomberg is reporting that Rahn & Bodmer Co., the Swiss private bank established by silk traders in 1750, announced that it is cooperating with a U.S. Department of Justice probe into cross-border accounts of American clients. Rahn & Bodmer is classified as a “Category 1” Swiss bank and is therefore ineligible for the Department of … Continue Reading

U.S. DOJ Offers Landmark Non-Prosecution Deal for Swiss Banks

On August 29, 2013, the U.S. Department of Justice announced a program, supported by the Swiss government, to encourage all Swiss banks to admit their role in U.S. tax evasion in exchange for non-prosecution agreements and substantial monetary penalties. To participate, Swiss banks have to undertake internal investigations and make a complete disclosure of their … Continue Reading

Prison for Executives of Professional Employer Organization

The AP is reporting today that two West Virginia staffing agency executives have been sentenced to prison in a tax evasion scheme.  Sixty-year-old Daniel Hovis of Whittier, N.C., was sentenced to two years in prison, while 62-year-old Janice Hensley of Charleston, W.V., was sentenced to one year and eight months.  They pleaded guilty in May … Continue Reading

IRS Announces Selection of New “Director, International Strategy”

The IRS recently announced that private practitioner Diana Wollman will begin work as “Director, International Strategy” on September 16, 2013.  According to the IRS, Wollman will serve as the principal advisor to the Deputy Commissioner (International) on a wide range of high-level and sensitive international issues and will oversee the development and implementation of all … Continue Reading

California Man Pleads Guilty to Hiding Money in Israeli Banks

Tax Analysts Tax Notes is reporting that Aaron Cohen of Encino, Calif., pleaded guilty today in the U.S. District Court for the Central District of California to conspiracy to defraud the United States. According to court documents, Cohen, a U.S. citizen, maintained undeclared bank accounts at two international banks headquartered in Tel Aviv, Israel, identified … Continue Reading