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Criminal Investigation

Tax Court found taxpayer had no unreported income despite tax evasion conviction

Tax Court found taxpayer had no unreported income despite tax evasion conviction

Senyszyn, (2016) 146 TC No. 9 The Tax Court has concluded that a taxpayer who misappropriated funds from a business associate and failed to report the misappropriated funds as income had no unreported income for the year because he repaid to the associate amounts in excess of those that he took. Accordingly, it found that […]

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U.S. man accused of using Craigslist to find fake tax dependents

U.S. man accused of using Craigslist to find fake tax dependents

KANSAS CITY, Mo. (Reuters) – A Missouri man has been charged with filing false U.S. tax returns after allegedly using Craigslist to find three children he could falsely claim as dependents, a federal prosecutor announced on Wednesday. A U.S. grand jury in Springfield, Mo., indicted Raheem McClain, 37, of Ozark, Missouri, on three counts of […]

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Texas tycoon Wyly engaged in massive tax fraud, IRS tells court

Texas tycoon Wyly engaged in massive tax fraud, IRS tells court

DALLAS (Reuters) – Texas tycoon Sam Wyly engaged in “lies, deception and fraud” in a years-long scheme to dodge taxes on $1.1 billion held in offshore trusts, a lawyer for the Internal Revenue Service said on Wednesday. The IRS made those claims at the start of a trial in federal bankruptcy court in Dallas in […]

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IRS Criminal Investigation Releases Fiscal Year 2015 Annual Report

IRS Criminal Investigation Releases Fiscal Year 2015 Annual Report

WASHINGTON — The Internal Revenue Service announced the release of its IRS Criminal Investigation (CI) annual report, reflecting significant accomplishments and enforcement actions taken in fiscal year 2015.   Focusing on tax-related identity theft, money laundering, public corruption, cybercrime and terrorist financing, IRS CI initiated 3,853 cases in FY 2015. “Our criminal investigators continue to bring […]

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Supreme Court won’t review case involving IRS compelled production of foreign bank records

Supreme Court won’t review case involving IRS compelled production of foreign bank records

Chabot, (CA 3 7/17/2015) 116 AFTR 2d 2015-5270, cert denied 11/30/2015 The Supreme Court has declined to review a decision of the Court of Appeals for the Third Circuit which held that the “required records” exception to the Fifth Amendment privilege against self-incrimination applies to allow IRS to summon foreign bank account records. Note: Similar conclusions […]

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Washington Alert – IRS-CI Fiscal Year 2015 Annual Business Report; TIGTA report on IRS’s Identity Protection Specialized Unit (IPSU); Tax Policy Center report on “Major Tax Issues in 2016”

Washington Alert – IRS-CI Fiscal Year 2015 Annual Business Report; TIGTA report on IRS’s Identity Protection Specialized Unit (IPSU); Tax Policy Center report on “Major Tax Issues in 2016”

IRS Criminal Investigation (CI) launched 3,853 investigations, recommended prosecutions in 3,289 cases, and generated 3,208 informations/indictments in fiscal year 2015, the agency announced on Dec. 3. (IRS-CI Fiscal Year 2015 Annual Business Report) In a statement accompanying the release of the report, the head of CI praised the efforts of his personnel but also shined […]

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CCA addresses civil tax issues relating to year taxpayer was subject of criminal conviction

CCA addresses civil tax issues relating to year taxpayer was subject of criminal conviction

Chief Counsel Advice 201545016 In Chief Counsel Advice (CCA), IRS has untangled several civil tax issues relating to a number of years for which a taxpayer filed invalid or otherwise faulty returns, was criminally charged with filing false claims against the U.S., and pled guilty to one such count. Among other things, the CCA concluded […]

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Payment of option fee in Colorado pawnshop transaction may trigger cash reporting

Payment of option fee in Colorado pawnshop transaction may trigger cash reporting

Chief Counsel Advice 201536022 In e-mailed Chief Counsel Advice (CCA), IRS has concluded that the payment fee in connection with a Colorado pawnshop contract for purchase is a “retail sale” that can trigger the Code Sec. 6050I reporting requirement for cash receipts of more than $10,000. Background.Code Sec. 6050I generally requires each person engaged in […]

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Only one aiding/abetting penalty for false statements on retirement plan application

Only one aiding/abetting penalty for false statements on retirement plan application

Chief Counsel Advice 201531015 In Chief Counsel Advice, IRS has drawn several conclusions with respect to the Code Sec. 6701 aiding and abetting penalty. For example, it concluded that it can assess only one Code Sec. 6701 penalty against an individual who submits false documents in support of a retirement plan’s application for qualified status, […]

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Tax Court oks individual’s business deductions including legal fees for criminal defense

Tax Court oks individual’s business deductions including legal fees for criminal defense

McMillan, TC Memo 2015-109 The Tax Court has allowed business deductions to an individual taxpayer for: a) legal fees that included fees paid to defend the taxpayer against criminal charges; and b) interest paid with respect to a loan that, in a prior Tax Court case, the Court ruled wasn’t a business loan.  Click here […]

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Washington Alert – DOJ reaches deal with Finter Bank; Tax Benefits to Military; CI’s new cybercrime unit

Washington Alert – DOJ reaches deal with Finter Bank; Tax Benefits to Military; CI’s new cybercrime unit

The Justice Department (DOJ) announced on May 15 that it has reached a resolution with Finter Bank Zurich AG under the department’s Swiss Bank Program. (15-622) The bank must pay a $5.41 million penalty. As described by DOJ, the Swiss Bank Program provides a way for Swiss banks to resolve potential criminal liabilities in the […]

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IRS clarifies its position on civil forfeitures in uncharged structuring cases

IRS clarifies its position on civil forfeitures in uncharged structuring cases

Following a slew of recent negative press involving IRS’s use of civil forfeiture laws, IRS’s Chief of Criminal Investigation (CI) has issued a statement stating that the agency would no longer pursue the seizure and forfeiture of funds associated solely with legal source “structuring” cases unless there are exceptional circumstances that warrant such seizures or […]

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TIGTA Report: The IRS Parallel Investigations Process Needs Improvement

TIGTA Report:  The IRS Parallel Investigations Process Needs Improvement

TIGTA issued its report – The Parallel Investigations Process Needs Improvement – Processes for communication and coordination of parallel investigations between the applicable IRS’s civil compliance functions and its Criminal Investigation (CI) could be improved. The civil compliance functions are generally following the procedures that require them to communicate with CI their intent to conduct […]

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Former President of Qualcomm’s Global Business Operations Indicted for Insider Trading

Former President of Qualcomm’s Global Business Operations Indicted for Insider Trading

As announced by the DOJ, Former President of Qualcomm’s Global Business Operations Indicted for Insider Trading, Executive Jing Wang Used Offshore Entities and Secret Brokerage Accounts to Conceal and Disguise Illicit Profits. Jing Wang, 51, of Del Mar, Calif., a former Executive Vice President and President of Global Business Operations for Qualcomm Inc., was charged […]

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Naples Residents Plead Guilty to Tax Fraud for Failing to Pay Employment Taxes

Naples Residents Plead Guilty to Tax Fraud for Failing to Pay Employment Taxes

As reported by the DOJ, “Naples Residents Plead Guilty to Tax Fraud for Failing to Pay Employment Taxes,” the Justice Department and the Internal Revenue Service (IRS) announced that Anthony Chaudhuri and Margaret Chaudhuri, of Naples, Fla., pleaded guilty to one count each of conspiracy to defraud the United States.  Here is the plea agreement […]

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Brothers who Made ‘Contributions’ to Orthodox Jewish Organizations Plead Guilty to Tax Evasion after Taking Secret Refunds from Groups

Brothers who Made ‘Contributions’ to Orthodox Jewish Organizations Plead Guilty to Tax Evasion after Taking Secret Refunds from Groups

As reported by the Department of Justice press release, two brothers who made tens of thousands of dollars of contributions to charitable organizations operating under the umbrella of a New York-based orthodox Jewish group known as Spinka pleaded guilty today to tax fraud for taking tax deductions for contributions that were refunded by the non-profits. […]

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TIGTA: Actions Are Needed to Accurately Reflect Criminal investigation’s Fraud Referral Evaluation Period And Improve The Criminal Fraud Referral Process

TIGTA: Actions Are Needed to Accurately Reflect Criminal investigation’s Fraud Referral Evaluation Period And Improve The Criminal Fraud Referral Process

As reported by TIGTA, “Actions Are Needed to accurately reflect Criminal investigation’s Fraud Referral Evaluation Period and Improve The Criminal Fraud Referral Process.” IMPACT ON TAXPAYERS Tax fraud is a deliberate and purposeful violation of Internal Revenue laws by those who do not file and properly report their income and expenses. When criminal fraud is […]

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IRS Criminal Investigation Issues Fiscal 2012 Report

IRS Criminal Investigation Issues Fiscal 2012 Report

IRS Criminal Investigation (CI) released its Annual Report for fiscal 2012, highlighting strong gains in enforcement actions and penalties imposed on convicted tax criminals.  Highlights of the report include: Investigations initiated and prosecution recommendations were both up nearly 9 percent in fiscal 2012 compared to the prior year. Filings of indictments and other charging documents […]

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The $1.7 million tax refund that wasn’t – Donus R. Sroufe convicted of tax fraud

The $1.7 million tax refund that wasn’t – Donus R. Sroufe convicted of tax fraud

As reported in the WS Journal, the IRS does not take kindly to liars – especially when the fibs have seven figures.  A federal jury convicted a Georgia man Wednesday for using a phony Treasury bond to claim he was owed a $1.7 million tax refund, according to the Atlanta Journal-Constitution. Prosecutors said Donus R. […]

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What are your chances for being audited? IRS’s 2012 data book provides some clues

What are your chances for being audited? IRS’s 2012 data book provides some clues

IRS has issued its annual data book, IR 2013-32, 2012 Data Book, which provides statistical data on its fiscal year (FY) 2012 activities. As this article explains, the data book provides valuable information about how many tax returns IRS examines (audits) and what categories of returns IRS is focusing resources on, as well as data […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney