Partner Jeremy H. Temkin Published Criminal Tax Offenses Chapter in Law Journal Press Treatise Entitled, White Collar Crime: Business and Regulatory Offenses
NEW YORK, October 30, 2020 - Morvillo Abramowitz partner Jeremy H. Temkin published a chapter entitled Criminal Tax Offenses in the Law Journal Press treatise White Collar Crime: Business and Regulatory Offenses. The chapter discusses considerations for counsel representing clients in criminal tax investigations, including the investigative tools available to the IRS and potential barriers to the IRS’s broad investigative authority. The chapter further addresses strategic matters for counsel representing targets in criminal tax cases, including the IRS’s recently revised Voluntary Disclosure practice, which provides clients who are not yet under investigation an avenue to avoid prosecution. Additionally, the chapter reviews the statutes commonly used to prosecute federal criminal tax offenses in detail, including the applicable statutes of limitations and venue provisions, as well as the methods that prosecutors use to prove that a taxpayer underreported his or her income. Finally, the chapter considers issues relating to sentencing in criminal tax cases, including both the Sentencing Guidelines applicable to tax offenses and the availability of non-Guidelines sentences under 18 U.S.C. § 3553(a).
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