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Posts Tagged failure to file returns

Do You Have The Right To Rely on IRS Forms? Court Says “Maybe” – FBAR Post

A federal jury in South Bend, Indiana convicted James Simon of filing false tax returns and of failing to file FBARs. As regular readers of this blog know, the willful failure to file an FBAR is a felony. Following his conviction, Simon appealed. In a lengthy opinion, the US. Seventh Circuit Court of Appeals upheld [...]

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Feds Proposed New Felony Tax Crime Has Implications For Those Overseas

by Brian Mahany Tax evasion is a felony. Prosecutors must prove that the person accused possessed a willful intent to evade taxes and committed some affirmative or overt act of evasion. Mere failure to pay taxes or file returns are misdemeanors punishable by no more than a year in prison. The difference is the required [...]

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IRS Criminal Investigations – Will I Get Charged?

by Brian Mahany Everyone who gets the proverbial knock on the door from the guys and girls with guns and badges (IRS CID) asks this question. Once a tax case is referred to the IRS Criminal Investigation Division, the chances of prosecution are high. Unfortunately, few clients seek legal counsel until a formal investigation has [...]

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