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.