Penalties, including but not limited to:

  • Criminal penalties in 18 U.S.C. as well as 26 U.S.C.;
  • The sentencing guidelines;
  • Return reporting crimes:
    • Tax evasion under 7201;
    • False return under 7206(1);
    • Jurat issues under 18 U.S.C. 1621;
    • Aiding and assisting under 7206(2); and
    • Failure to file a return under 7203;
  • Tax administration crimes:
    • Tax evasion under 7201;
    • Concealing assets under 7206(4);
    • Impeding administration under 7212(a); and
    • False statements under 18 U.S.C. 1001;
  • Statute of limitations on crimes under 6531 and 18 U.S.C. 1001;
  • Assisting as co-counsel in criminal investigations and prosecutions;
  • Voluntary disclosure:
    • Assisted several clients in resolving son-of-boss transactions under the settlement initiative thereto;
    • Assisted several clients in the 2011 offshore voluntary disclosure initiative in resolving disputes and penalties thereto regarding offshore assets; and
    • Assisted several clients in the 2012 offshore voluntary disclosure initiative in resolving disputes and penalties thereto regarding offshore assets.
  • Civil penalties
    • Fraudulent return under 6663;
    • Preventing clear and convincing evidence;
    • Fraudulent failure to file a return under 6651(f);
    • Accuracy related penalties under 6662;
    • Fighting standards such as negligence and substantial understatement;
    • Providing substantial authority;
    • Substantial valuation misstatement penalty under 6662;
    • Arguing innocent spouse relief, as well as reasonable cause, to a large variety of penalties;
    • Failure to file penalties under 6651;
    • Failure to pay penalties under 6651;
    • Frivolous returns under 6702;
    • Aiding and abetting under 6701; and
    • Penalty handbook.