Al Capone apparently said, “they can’t collect legal taxes from illegal money.” He later learned that they can. Last week, the Fifth Circuit provided a reminder that stolen money is income, just like money obtained through honest means. Sun v. Comm’r, No. 16-60270, 2018 U.S. App. LEXIS 1187 (5th Cir. Jan. 18, 2018).
A foreign friend sent Jerry Sun $19 million dollars to invest on his behalf in a loose arrangement that was not committed to writing. Sun spent $6 million on personal expenses, parked $4 million in the accounts of a company he controlled, and invested the balance in his own brokerage accounts where it was intermingled with his own funds.… Read More