criminal tax investigation: Criminal Tax New Haven, CT: IRS Arrests Michael Avenatti at Hearing - 01/15/20 06:37 AM
We routinely represent taxpayers in civil and criminal tax cases.  We wanted to let everyone know that  IRS agents arrested embattled attorney Michael Avenatti in Los Angeles late Tuesday during a break in a hearing before the California State Bar, the U.S. attorney's office confirmed , saying he allegedly violated the terms of his pretrial release on charges he embezzled client funds.
Michael Avenatti, famous for representing Adult Actress Stormy Daniels and had been positioning himself for a run for President, was arrested Tuesday, cutting short a hearing on whether his law license should be suspended while the California State Bar investigates … (0 comments)

criminal tax investigation: Criminal Tax Part 1: Where Criminal Tax Cases Come From - 09/25/18 03:35 AM
Episode 35 of the Tax Rep Network Podcast is now out, and on it I am joined by Jim Olson, Former IRS Criminal Investigation Supervisory Special Agent who now focuses his practice on forensic investigations and reconstruction.  During this episode Jim pulls back the curtain on where criminal tax cases come from for IRS-CI, and how CI evaluates which cases it is going to take and investigate and which ones it simply kills, and why that is?  Most importantly, he provides advice to taxpayers and practitioners on what to do if IRS-CI agents knock at your door one morning!
The episode can … (0 comments)

criminal tax investigation: 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 investigation: Stamford, Connecticut or Elsewhere, Meet the new IRS SEP Examiner - 06/08/13 07:22 AM
The focus of our practice is civil and criminal taxpayer representation, and whether in Stamford, Connecticut or elsewhere, the IRS has stepped up its focus on identifying and prosecution criminal tax matters.  What has developed is a new Special Enforcement Program (“SEP”), and its examiners may be coming to taxpayer near you.
What is “SEP”? 
SEP is a specialized compliance program within the IRS Small Business/Self-Employed Operating Division directed toward that segment of the population which derives substantial income from either legal or illegal activities and intentionally understate their income. 
When we represent taxpayers before the IRS or the Department of … (0 comments)

criminal tax investigation: 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 investigation: CT DRS Criminal Prosecutions in Stamford, CT: Connecticut Department of Revenue Services (“DRS”) continues its criminal tax enforcement in Stamford, CT and elsewhere. - 01/14/12 12:02 AM
We frequently represent taxpayers in criminal tax cases with the Connecticut Department of Revenue Services (“DRS”) throughout Connecticut, including Stamford, Connecticut.   We can assure you that the DRS has increased its focus on enforcement and prosecuting businesses for the willful failure to file sales tax returns or the filing of false sales tax returns, as well as Larceny and filing of false income tax returns. 
In the last quarter of 2011 the CT DRS has confirmed its Tax Enforcement Agents made 53 arrests, many of which were for cigarette infractions and failing to operate without a sales tax permit.  The DRS … (0 comments)

criminal tax investigation: 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 investigation: 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)

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

Eric L. Green

Your IRS Tax Litigator

New Haven, CT

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Tax Rep LLC

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

Office: 203-285-8545

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