The Internal Revenue Service has broad authority to examine books and records and interview witnesses for the purposes of determining the liability of any person for taxes, penalties or interest and collecting any liability.  This authority includes the power to issue summonses, including to third-parties.  Under Powell v United States, 379 U.S. 48 (1964), the […] Read More…

While many people are familiar with the phrase “Cash is King,” dealing in cash can, and often does, take on new meaning when it comes to the IRS. There is, of course, the obvious obligation to ensure that any, and all, cash received as income is properly reported annually on the appropriate tax return. However, that […] Read More…

The United States Sentencing Commission  recently released a study of sentencing of federal offenders convicted of economic crimes.  The study included within the category of “economic crimes” thus sentenced under §2B1.1 of the United States Sentencing Guidelines (USSG), tax crimes and identity theft.  Tax crimes encompass Title 26 (Internal Revenue Code) violations, conspiracies to defraud […] Read More…