Firm name
September 2014
Greetings!

Sometimes understating income is just carelessness. Sometimes its tax fraud or tax evasion. People don't always realize that tax fraud or tax evasion can lead to time in jail.

Convincing judges to sentence defendants to prison for criminal tax evasion continues to be a priority for the Department of Justice where taxpayers have willfully underreported their income or made false statements to the IRS revenue agents regarding their tax liabilities, as shown by unrelated decisions handed down against Abdelhamid M. Horany and Robert C. Sathre.

Horany, a business owner, admitted to underreporting his income by approximately $175,000, which resulted in his underreporting his tax due and owing by over $60,000 in 2007 alone. In total, Horany underreported his tax due by more than $145,000; he was sentenced to 12 months in prison for his actions. Sometimes taxpayers try to convince themselves that the IRS won't go after them because they are "minnows." This case is a warning that it is not necessary to evade millions of dollars in taxes in order to be prosecuted for tax evasion.

Sathre, also a business owner, was a much bigger fish; he pled guilty to charges of tax evasion and was sentenced to 36 months in prison and was ordered to pay $3,113,882 in restitution for willfully evading payment of his taxes for 1995 and 1996. According to the Department of Justice press release, Sathre concealed income from a property he sold, for which he received over $3 million in installment payments. Sathre compounded the problem by sending over $500,000 during 2005 and 2006 to an offshore bank account in the Caribbean, and later wired $900,000 from the sale of another property to the same offshore account in an attempt keep the funds out of the reach of the IRS. In addition, Sathre supplied the Caribbean bank with false declarations and false promissory notes and also claimed he was neither a citizen nor a resident of the United States. Although not mentioned in the press release, one would assume that Sathre also failed to file  Foreign Bank Account Reports (FBARs) on TD-F 90-22.1 (now known as FinCEN Form 114). These criminal tax cases (among many others) demonstrate that the IRS takes the issue of underreporting income very seriously and will not hesitate to press for a prison sentence in cases involving tax evasion. 

 

Call our experienced criminal tax attorneys at 1-800 Tax Litigator (1-800-208-6200) for a confidential consultation to discuss available options if you have been contacted by the IRS in connection with civil or criminal tax fraud or tax evasion, or any other high stakes tax problem.

 

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Picture of Dennis N. Brager
Dennis N. Brager, Esq.
 
Former IRS Senior Trial Attorney
Nationally Recognized California State Bar Certified Tax Specialist
dbrager@bragertaxlaw.com

310.208.6200
Upcoming Speeches & Webinars 
  
Dennis will be speaking at the following upcoming events.
 
"New FBAR Reporting Regulations Navigating Offshore Voluntary Disclosure Programs"
10:00 am- 11:30 am
September 10, 2014

"Changes to IRS Offshore Voluntary Disclosure Program"
12:00 pm- 1:30 pm 
September 11, 2014

"Helping Individuals Whose Spouses Are On The IRS Deadbeat List"
11:00 am- 12:00 pm
September 18, 2014

"Dialing for Dollars - the IRS Collection Process"
10:30 am - 11:20 am 
October 28, 2014

   In the News

  

 "Is It Time to Come Clean?"

 Accounting Today

 August 2014

 

"FBAR Filing Date Approaching" 

Accounting Today

May 2014

 

"Brager Sponsors FBAR Contest"
Accounting Today

May 2014

 

 

Previous Events

Dennis' webinar, "The IRS Collection Process: What You Need to Know to Advise Your Clients" is available on the Brager Tax Law Group Website: 
Click here for the Recording
Click here for the PowerPoint

Dennis' webinar, "Innocent Spouse Relief: Fact or Fiction?" is available on the Brager Tax Law Group Website:
Click here for the Recording 
Click here for the PowerPoint

Recent Blog Posts 
  
July 2014


 

 Our Services

The Brager Tax Law Group is a tax litigation and tax controversy law firm, which represents clients with tax problems and tax disputes with the IRS, the California Franchise Tax Board (FTB), the State Board of Equalization (SBE) and the Employment Development Department (EDD). All of the firm's tax lawyers are former trial attorneys with the IRS. 

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Brager Tax Law Group
10880 Wilshire Boulevard
Suite 880
Los Angeles, California 90024
Tel: (310) 208-6200
Fax: (310) 478-8030