criminal tax: Tax Rep Network Podcast: The Lifecycle of a Criminal Tax Case - 02/10/22 05:34 AM
On this week’s podcast episode Eric is joined by Gwen Moore and Ajay Gupta to walk through how a criminal tax works, from referral to sentencing.
Check out the podcast on ITunes, Google Podcasts, Apple Podcasts, Spotify or on our Podcast Page Here!
Want to contact Gwen?  She can be found here trying to save taxpayers.   https://www.mooretaxlawgroup.com/attorney/moore-guinevere-m/
Ajay Gupta can be contacted here:  https://www.mooretaxlawgroup.com/attorney/ajay-gupta/ 
Interested in joining Tax Rep Network and building an unbelievable Tax Rep practice? Come check out Tax Rep here!
Want to check out a special offer from bench on outsourced bookkeeping and forensic reconstruction?  https://bench.co/taxrep 
Use CallENQ to get through to the IRS in under 3 minutes!  Special Offer … (0 comments)

criminal tax: New Haven Criminal Tax: 3rd Annual Conference on May 16th! - 02/27/19 05:02 PM
Join us for our 3rd annual full-day criminal tax conference, where attendees will learn everything they could want to know about the criminal tax process!  This year's conference is named "Shopping the Preparer" which is when IRS Criminal Investigations sends in undercover agents to see if a tax preparer is playing games.
So join us on May16th either in person or via live webcast and catch all the entertainment as our star line-up of speakers covers everything from the criminal tax process threough prosecuting bad preparers!
Eric L. Green, Esq.
Green & Sklarz LLC
700 State Street, Suite 100
New Haven, CT 06511
www.gs-lawfirm.com
Ph. (203) 285-8545
(0 comments)

criminal tax: New Haven, CT: What to Do If You Have Not Filed Tax Returns - 02/20/19 04:37 PM
I represent taxpayers in New Haven and the rest of Connecticut who have civil and criminal tax issues, and have recently seen an uptick in those folks coming to us who have not filed tax returns, some for many years.  In fact, the non-filer issue is a major priority for the IRS, who have stated publicly that they have identified more than 7 Million taxpayers who have failed to file returns, and that the IRS plans to roll-out an initiative to target these tax scofflaws.
In addition, it is worth noting that the willful failure to file a tax return is a … (0 comments)

criminal tax: Ringleader of Stolen Identity Tax Refund Fraud Gets 30 Years in Prison - 03/08/18 06:39 PM
Over 8,800 Identities Stolen from the U.S. Army, Alabama State Agencies and Georgia Businesses
We focus our practice on tax matters, and I in particular on civil and criminal tax controversy issues.  I can assure those of you who have never had to go through the pain of unwinding your identity being stolen that saying its unpleasant is putting it mildly.  Therefore it was with much pleasure I read the Department of Justice's announcement today that the leader in a huge identity theft ring was sentenced to 30-years in prison!   
A Phenix City, Alabama, resident was sentenced today to 30 years in … (0 comments)

criminal tax: Criminal Tax in New Haven, CT: What is Tax Evasion? - 08/25/17 03:35 AM
When it comes to tax crimes in New Haven, Connecticut, New York city or elsewhere, Tax Evasion is always considered the big kahuna of tax crimes.  So what is "Tax Evasion"?
We handle civil IRS cases and criminal tax cases all over the United States, and therefore see a lot of what taxpayers do and don't do that later get them into trouble.  One thing I do notice is the confusion about what "Tax Evasion" actually is, and that most practitioners do not realize there are two forms of tax evasion: Evasion of Liability and Evasion of Collection.  More and more, the … (0 comments)

criminal tax: NY Criminal Tax: Man Charged with Tax Evasion from Foreign Accounts. - 09/28/16 05:37 AM
We focus on helping taxpayers handle civil and criminal tax problems.  The Department of Justice just announced that a New York City man pleaded guilty today to a criminal information charging him with tax evasion for tax years 2003 through 2005 and 2007 through 2010.  
“Mr. Hager concealed over $7.3 million in undeclared foreign accounts in Switzerland and Israel and used a sham British Virgin Island entity in order to evade over $650,000 in U.S. taxes,” said Principal Deputy Assistant Attorney General Caroline D. Ciraolo, head of the Justice Department’s Tax Division. “As this case demonstrates, the Department and the Internal … (1 comments)

criminal tax: Streamlined Compliance for Non-Resident U.S. Taxpayers, Part IV - 01/17/14 09:05 PM
The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad.  
Part I of this series discussed the new streamlined compliance procedures for U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank Account Reports (FBARs), Form TD F 90-22.1, but have recently become aware of their filing obligations and now seek to come … (0 comments)

criminal tax: New York Governor Announces Tax Relief for Businesses and Individuals - 01/15/14 12:56 AM
The focus of our practice is civil and criminal taxpayer representation, and we see many taxpayers in Greenwich, Connecticut  and New York who are struggling with back tax burdens.
New York Gov. Andrew M. Cuomo has announced details of a more-than-$2-billion tax relief proposal that targets corporate (franchise) income, personal income, property, and estate taxes, as well as the temporary utility assessment, and is designed to increase economic opportunity and attract and grow businesses across the state. The plan also includes simplification of the tax code. Key points of the proposal are:
the elimination of the corporate income tax on upstate … (0 comments)

criminal tax: Criminal IRS Tax Referrals in Stamford, CT and New York, NY - 11/27/13 09:58 PM
The focus of our practice is civil and criminal taxpayer representation, and see many taxpayers in Stamford, Connecticut referred to the IRS Criminal Investigation division because of shoddy bookkeeping.  It is critical that taxpayers maintain good records or face serious tax bills, or even criminal tax prosecution.
Many IRS criminal tax cases begin as routine civil IRS examinations and, when the examiner is confronted with either a lack of records or bookkeeping records that cannot be easily reconciled to the federal IRS tax return, thoughts of a referral to the criminal investigation division begin to grow.
The goals for any taxpayer … (0 comments)

criminal tax: My old Profile - 08/22/13 03:00 PM
Old Profile Contents
About me:
Past Chair of the ABA Closely Held Businesses Tax Committee Chair of the Executive Committee of the Tax Section of the Connecticut Bar Association Invited Member of the Hartford Tax Club Member of the American Bar Association Member of the Connecticut and Massachusetts Bar Associations Member of the United States Tax Court Bar Member of the Federal Court of Claims Bar Member of the Estate & Probate Section and Tax section of the CBA
Certifications:
Advanced Criminal Tax Issues Part 2: The Tax Man Cometh, EA Journal, Vol. 30, No. 6, September-October 2012 The Eggshell … (0 comments)

criminal tax: Criminal Tax in Stamford CT: An Introduction to the crime of Tax Evasion and defending taxpayers charged with it in Stamford, Connecticut - 06/02/13 12:40 PM
We frequently represent taxpayers and accountants in criminal tax matters, and whether in Stamford, Connecticut or elsewhere, the Department of Justice and IRS have both historically regarded Tax Evasion as the most important criminal tax statute.  It is also the criminal tax statute with the greatest impact for deterrence.
Under IRC § 7201, Tax Evasion has three elements:
1. Willfulness
2. The existence of a tax deficiency
3. An affirmative act constituting evasion or an attempted evasion of tax
The definition of willfulness is the “violation of a known legal duty.”  The willfulness test is a subjective one, and what I … (0 comments)

criminal tax: IRS Summons Enforcement Stamford, CT: What happens if I don’t show up for an IRS Summons? - 01/23/13 12:43 AM
The focus of our practice is civil and criminal taxpayer representation, and whether in Stamford, Connecticut or elsewhere, one of the most power tools the IRS has at its disposal to gather taxpayer information is its power to issue an administrative Summons. 
The IRS generally uses its administrative summons power to gather information – both written records and testimony – when it is seeking tax returns or conducting a tax investigation.
When we represent taxpayers before the IRS or the Department of Justice Tax Division, we often get asked the question from our clients: “What if I don’t show up?”
If … (1 comments)

criminal tax: IRS Summons Stamford, CT: The IRS’s ability to use its Summons power to obtain taxpayer information in Stamford, Connecticut. - 01/23/13 12:41 AM
The focus of our practice is civil and criminal taxpayer representation, and whether in Stamford, Connecticut or elsewhere, one of the most power tools the IRS has at its disposal to gather taxpayer information is its power to issue an administrative Summons. 
When we represent taxpayers before the IRS or the Department of Justice Tax Division, we often have to explain the administrative powers the IRS examiners or criminal investigators have.  IRC § 7602 allows the IRS to examine records, issue a summons either for the records or the taxpayer themselves to appear, and take testimony.  This is often done when … (0 comments)

criminal tax: New Haven Connecticut Criminal Payroll Tax Prosecutions: The factors the IRS looks for in deciding to pursue a criminal employment tax case for unpaid payroll taxes. - 12/09/12 11:42 AM
Historically there have been few criminal employment tax prosecutions, however the IRS Criminal Investigation Division has suddenly focused on this area.  The number of prosecutions for criminal employment tax violations under IRC § 7202 has swung up significantly in the last 2 years.
We represent taxpayers in a number of criminal tax prosecutions, and can tell taxpayers that the things that the IRS Criminal Investigation Division looks for when deciding to pursue a criminal payroll tax case against a business owner.   
Those things they look for include:
<!--[if !supportLists]-->•       <!--[endif]-->Recidivism: Where the taxpayer has opened a series of companies that … (0 comments)

criminal tax: IRS Criminal Tax Stamford CT: What causes an IRS audit to be referred for criminal prosecution in Stamford, CT and elsewhere? - 02/25/12 10:29 AM
We frequently represent taxpayers before the IRS during routine audits in Stamford, Connecticut, as well as criminal tax investigations and eggshell audits (civil audits where tax fraud exists but the IRS has not found it yet).  I am often asked what causes an IRS examiner to send a case to the criminal investigation division (“CI”)?
The Internal Revenue Manual (“IRM”) states that an IRS tax auditor should refer the case for criminal investigation when there are “firm indications of fraud.”
Great: so what does that mean?
There are a number of items that may raise an examiner’s suspicion of tax fraud: … (2 comments)

criminal tax: Connecticut and Massachusetts Tax: Attorney Eric Green to Speak at the NAEA’s National Tax Practice Institute in Las Vegas in August 2012 - 01/25/12 12:12 AM
Attorney Eric Green will speak at the National Association of Enrolled Agent’s National Tax Practice Institute being held at Mandalay Bay in Las Vegas, Nevada this coming August 2012.  Attorney Green will be lecturing on Advanced Criminal Tax Issues and will be covering all the major Civil and Criminal Tax Representation developments that have occurred in the last 12 months.
The discussion will cover:
Eggshell Audits The 7525 Accountant-Client Privilege Kovel Accountants The IRS Criminal Tax Investigation Sentencing issues in Criminal Tax cases Recent Criminal Tax prosecutions If you have any questions or wish to speak to Eric Green, feel free … (0 comments)

criminal tax: IRS Stamford CT: IRS Releases Guidance on Foreign Financial Asset Reporting - 12/15/11 07:56 AM
We frequently get involved in helping taxpayers sort out their foreign bank account issues with the IRS in Stamford, CT and elsewhere.  The Internal Revenue Service in coming days will release a new information reporting form that taxpayers will use starting this coming tax filing season to report specified foreign financial assets for tax year 2011.
Form 8938 (Statement of Specified Foreign Financial Assets) will be filed by taxpayers with specific types and amounts of foreign financial assets or foreign accounts. It is important for taxpayers to determine whether they are subject to this new requirement because the law imposes significant penalties … (0 comments)

criminal tax: Stamford CT IRS Criminal Tax: Venue for Failure to File FBAR Lies in Any District that Houses an IRS Office - 12/07/11 12:59 PM
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England.  In United States v. Bradley, 644 F.3d 1213 (11th Cir. 2011), the Eleventh Circuit held, inter alia, that venue for failure to file an FBAR properly lies in any district that houses a local IRS office, so long as the chosen venue does not create a constitutional hardship for the defendant.
As discussed above, the Bradleys and their company, Bio–Med Plus, Inc., engaged in multiple schemes to defraud the Florida and California Medicaid programs … (0 comments)

criminal tax: Stamford CT IRS Criminal Tax: Fifth Amendment Privilege Held to be Inapplicable to Subpoena for Foreign Bank Records Required under Bank Secrecy Act - 12/07/11 12:50 PM
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England.  In In re Grand Jury Investigation M.H. v. United States, 648 F.3d 1067 (9thCir.2011), the Ninth Circuit held that foreign bank account records required to be kept under the Bank Secrecy Act (“BSA”) fall within the Required Records Doctrine, thus rendering the Fifth Amendment privilege against self-incrimination inapplicable to a subpoena for these records.
When I am asked by clients about records demanded by the government, I often have to explain that records required … (0 comments)

criminal tax: FBAR Prosecution Hartford CT: US department of Justice Announces HSBC India Client Indicted for Filing False Tax Returns and Failing to Report Foreign Bank Account - 07/09/11 02:39 AM
Our firm represents a significant number of taxpayers in Hartford, Connecticut and elsewhere who have foreign bank accounts and would like to come forward and resolve the matter with the IRS and/or Department of Justice.
I cannot stress the importance of coming forward prior to the August 31st deadline, as the current stream of prosecutions coming out now do not bode well for those folks holding out.
The Department of Justice just released its latest announcement of a prosecution coming from HSBC in India.  Dr. Arvind Ahuja of Greendale, Wis., was indicted today by a federal grand jury in Milwaukee on … (1 comments)

 
Eric L. Green, Your IRS Tax Litigator (Tax Rep LLC)

Eric L. Green

Your IRS Tax Litigator

New Haven, CT

More about me…

Tax Rep LLC

Address: New Haven, CT, Stamford, CT, New York, NY, West Hartford, CT

Office: 203-285-8545

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