Speaking at the ABA’s Annual Criminal Tax Fraud and Tax Controversy Conference, senior officials from the Tax Division of the Department of Justice (DOJ) and the IRS Office of Chief Counsel described a variety of priorities for civil enforcement.
Consistent with prior indications that payroll taxes will be a significant area of focused criminal enforcement, Diana L. Erbsen, Deputy Assistant Attorney General for Appellate and Review, indicated that practitioners should anticipate civil actions for injunctive relief in payroll tax cases, followed by contempt proceedings to enforce those injunctions. Erbsen also indicated that the Financial Litigation Unit of the Office of Review, which focuses on collecting tax judgments, has received additional staff and is expected to be more active.… Read More
We are looking forward to attending the American Bar Association (ABA)’s 2015 Criminal Tax Fraud and Tax Controversy Conference in Las Vegas, NV from December 9 to December 11, 2015 (this Wednesday through Friday). This event is the annual gathering of the criminal tax defense bar combined with the ABA’s Fifth Annual National Institute on Tax Controversy. This program brings together government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax defense. Post & Schell is pleased to be a Bronze level sponsor of the conference, again.
I also am honored to be a panelist on the Criminal Tax Workshop during the afternoon of December 9; this is an annual panel involving private practitioners, federal prosecutors and former IRS agents that discusses strategies and techniques for handling sensitive civil examinations and criminal investigations, and defending a criminal prosecution.… Read More