Fifth Circuit Holds Prosecutorial Immunity Inapplicable to Post-Trial Disclosure of Federal Tax Records
In Lampton v. Diaz, 639 F.3d 223 (5th Cir. 2011), the Fifth Circuit held that prosecutorial immunity from suit did...
First Circuit Upholds Convictions under §§ 7206 and 7212 Based on False Responses to Question on IRS Form 990
In United States v. Mubayyid, No. 08–1846, 2011 WL 3849749 (1st Cir. Sept. 1, 2011), the First Circuit upheld the...
Third Circuit Emphasizes Distinction between Departure and Variance in Federal Sentencing of Tax Crimes
In United States v. Fumo, 655 F.3d 288 (3d Cir. 2011), the Third Circuit vacated the defendants’ sentence in part...
Eighth Circuit Upholds Below-Guidelines Sentence for Tax Evasion
In United States v. Renner, 648 F.3d 680 (8th Cir. 2011), the Eighth Circuit upheld the district court’s decision to...
Tenth Circuit Holds Unclaimed Deductions May Be Considered in Calculating Tax Loss at Sentencing for Tax Evasion
In United States v. Hoskins, 654 F.3d 1086 (10th Cir. 2011), the Tenth Circuit held, inter alia, that a sentencing...
District Court Finds Failure to Disclose IRS Investigation of Cooperating Witness Was Brady Violation and Grants New Trial
In United States v. Stevens, No. 10-200-01/02, 2011 WL 4344016 (W.D. La. Sept. 14, 2011), the U.S. District Court for...
Court Concludes that the Failure of the IRS To Disclose Documents to the Defense did not Violate Brady v. Maryland Because the Undisclosed Information was not Material
In United States v. Ellefsen, 655 F.3d 769 (8th Cir. 2011), the Eighth Circuit held that the government’s failure to...
Eleventh Circuit Holds Venue for Failure to File FBAR Lies in Any District that Houses an IRS Office
In United States v. Bradley, 644 F.3d 1213 (11th Cir. 2011), the Eleventh Circuit held, inter alia, that venue for...
Ninth Circuit Holds Fifth Amendment Privilege Inapplicable to Subpoena for Foreign Bank Records Required under Bank Secrecy Act
In In re Grand Jury Investigation M.H. v. United States, 648 F.3d 1067 (9thCir.2011), the Ninth Circuit held that foreign...
Worker Misclassification Serious Problem in Connecticut
Connecticut employers found by Department of Revenue Services (DRS) auditors to have misclassified their workers can face large tax assessments along...