Case Analysis : Tax Evasion

Now the following information is well documented and is presented for your review and edification. Do not try to fight the IRS in federal court, you will not win. The deception runs rampant throughout the executive, legislative and judicial branches.

The case of Rita Crundwell revolves around a town, other employees, and an auditor 's blind trust in a women, who clearly did not deserve the trust. Crundwell was the town Comptroller. The fraud resulted in 53 million dollars to be siphoned from the town 's funds in a time frame of 20 years. Crundwell covered her tracks with a fake bank account, fake invoices, and the party line of blaming the state for simply being behind on payments. There were many red flags during the two decades of this scheme, but due to the town 's small size and trusting attitude, they relied heavily on external audits, which were not up to par.

amount up front and she will be responsible for any additional higher cost incurred from a non-

a. Liability exceptions – tax avoidance or transfer was not for a bona fide business purpose

The investigation brought about the dissolution of the firm. Mr. Lomanno became fearful that this investigation would expose his embezzlement scheme. He decided to seek legal advice and he contacted a criminal attorney. The matter was taken up with the office of the US Attorney. He confessed for all his wrong doings and was offered a plea bargain which had a condition that he file his returns for the year 1986, 1987, and 1988 which had not being filed. The income from embezzlement was reported as “other income” and was in tunes of $45,007 for 1987 and $15,005 for 1988. Because he did not want the petitioner to know about this, he prepared the returns alone and tried to hand them in unsigned. The officers saw the unsigned part and wanted it signed. He went ahead and forged the signature of the petitioner. The petitioner came to learn of her husband’s embezzlement in the year 1990 through a probation officer and through a letter received from IRS revenue agent. The couple divorced in 1991. Mrs. Lomanno petitioned to be exempted from the tax return payments. In this case, the petitioner filed a subject motion for attorney’s fees and litigation costs.

In order to deduct her moving expenses, she must meet certain conditions outlined in Reg. 1.217-2 (c). Helen meets the first two requirements (relevance to work test and distance test) without any issue. The third requirement has not yet been met yet though. This requirement is a minimum period of employment. Since she is a full-time employee, she must work full-time in this general location for at least 39 weeks during the 12 month period after the move. This does not mean she is not required to remain employed at her current place of work to meet this test. Even though she does not meet this requirement yet, she can deduct these expenses on the current years return or the year the reimbursement is paid to her by her employer. If she recognizes the expenses on this year’s return and does not end up meeting the requirement, she will have to include the deductions she took on this year’s return in next year’s gross income.

There shall be allowed as a deduction the expenses paid during the taxable year, not compensated for by insurance or otherwise, for medical care of the taxpayer, his spouse, or a dependent (as defined in section 152 , determined without regard to subsections (b)(1) , (b)(2), and (d)(1)(B) thereof), to the extent that such expenses exceed 7.5 percent of adjusted gross income.

Wise-Holland Corporation, an S corporation, is split evenly between Marianne and Dory, two women with limited business knowledge. Wise Holland’s previous accountant of ten years was fired after Marianne received a notice of deficiency on her 2012 tax return due to $20,000 of disallowed flow through loss from Lucky Partnership, a small partnership deemed to have no profit motive; interest and a 20% penalty for substantial underpayment was also required, all of which Marianne paid immediately. She also signed a waiver extending her 2012 individual return statute of limitations three more years.

expenses she still has to pay a small percentage of the out‐of‐pocket costs, so she budgets $75.00 per month.

I appreciate the opportunity to advise you regarding the tax treatment for your loss of $25,406 in 2015 from your dog breeding activities. I understand that you decided to start breeding purebred terriers to keep yourself busy after your divorce with your husband in January. There are two possible ways to treat the loss under rulings in the Internal Revenue Code. One option is to treat your dog breeding activity as a business and deduct the losses on Schedule C, Profit or Loss from Business, of your individual income tax return. The second option is to treat your dog breeding as an activity not engaged in for profit, which does not allow you to deduct the

| The firm recommended an aggressive tax position to the client that is more likely than not to be legally allowed.

Normally the Internal Revenue Service conducts audits to a significant percentage of taxpaying citizens each year, this audits are perform to verify certain variances within the tax law and codes. The individual being audited does have a burden on

The first step under Trevino and Nelson is to gather the facts. In this case, the manager was not aware of or chose to ignore the facts surrounding the Italian tax system. The knowledge that the bank had with respect to the Italian tax system was therefore incomplete. The facts in this case included the mores surrounding the Italian system of tax collection and negotiation. The manager was informed that it would be advisable to declare a low amount of income and was subsequently informed of the need to hire a commercialista to handle the negotiations. The manager failed to heed this advice, in particular because he thought that these practices were unethical. The manager should have gathered the facts with respect to the mores and customs of the Italian tax collection system.

KPMG was one of the biggest accounting firms in the 90’s that with a lucrative end, would serve wealthy companies using forged revenues in order to avoid taxes. The accountants that worked for the firm were expected to meet certain quotas. Consequently, instead of trying to run an honest business they were trying to maximize the sales using all kinds of dishonest marketing approaches. KPMG employees used foreign banks as well as bogus law firm statements to preserve a legitimate business running. This accounting firm manipulated financial data of clients, costing the internal revenue service over 2.5 billion in lost tax revenue

Chief Justice M. Hameedullah Beg., Justice N. L. Untwalia, Justice P. N. Bhagwati, Justice P. S. Kailasam, Justice S. Murtaza Fazal Ali, Justice V. R. Krishna Iyer and Justice Y. V. Chandrachud.