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Criminal Tax

IRS Can Use John Doe Summons to Identify Taxpayers with Cryptocurrency

IRS Can Use John Doe Summons to Identify Taxpayers with Cryptocurrency

Apr 1, 2021

We represent taxpayers before the IRS and Department of Justice Tax Division, and have spoken frequently about the IRS increased use of both AI and John Doe Summonses to identify taxpayers who have either evaded reporting income and paying taxes, or those that have failed to disclose virtual currency in their financial affidavits, like with Offers-in-Compromise.

Because of the IRS’s efforts criminal tax referrals from the Collection Division are up 42% so far this year!

Check out our podcasts #91 and 93 on this topic here:  https://taxreptoolbox.com/tax-rep-network-podcast-main-page/

Today a federal court in the District of Massachusetts entered an order today authorizing the IRS to serve a John Doe summons on Circle Internet Financial Inc., or its predecessors, subsidiaries, divisions, and affiliates, including Poloniex LLC (collectively “Circle”), seeking information about U.S. taxpayers who conducted at least the equivalent of $20,000 in transactions in cryptocurrency during the years 2016 to 2020. The IRS is seeking the records of Americans who engaged in business with or through Circle, a digital currency exchanger headquartered in Boston.

“Those who transact with cryptocurrency must meet their tax obligations like any other taxpayer,” said Acting Assistant Attorney General David A. Hubbert of the Justice Department’s Tax Division. “The Department of Justice will continue to work with the IRS to ensure that cryptocurrency owners are paying their fair share of taxes.”

“Tools like the John Doe summons authorized today send the clear message to U.S. taxpayers that the IRS is working to ensure that they are fully compliant in their use of virtual currency,” said IRS Commissioner Chuck Rettig. “The John Doe summons is a step to enable the IRS to uncover those who are failing to properly report their virtual currency transactions. We will enforce the law where we find systemic noncompliance or fraud.”

Cryptocurrency, as generally defined, is a digital representation of value. Because transactions in cryptocurrencies can be difficult to trace and have an inherently pseudo-anonymous aspect, taxpayers may be using them to hide taxable income from the IRS. In the court’s order, U.S. Judge Richard G. Stearns found that there is a reasonable basis for believing that cryptocurrency users may have failed to comply with federal tax laws.

The court’s order grants the IRS permission to serve what is known as a “John Doe” summons on Circle. The United States’ petition does not allege that Circle has engaged in any wrongdoing in connection with its digital currency exchange business. Rather, according to the court’s order, the summons seeks information related to the IRS’s “investigation of an ascertainable group or class of persons” that the IRS has reasonable basis to believe “may have failed to comply with any provision of any internal revenue laws[.]” According to the copy of the summons filed with the petition, the IRS is requesting that Circle produce records identifying the U.S. taxpayers described above, along with other documents relating to their cryptocurrency transactions.

The IRS issued guidance regarding the tax treatment of virtual currencies in IRS Notice 2014-21, which provides that virtual currencies that can be converted into traditional currency are property for tax purposes. The guidance explains that receipt of virtual currency as payment for goods or services is treated as income and that a taxpayer can have a gain or loss on the sale or exchange of a virtual currency, depending on the taxpayer’s cost to purchase the virtual currency (that is, the taxpayer’s tax basis).

If you or someone you know have an IRS issue please feel free to contact me.

Eric L. Green
Green & Sklarz LLC
One Audubon Street, 3rd Floor
New Haven, CT 06511
Ph. (203) 285-8545
egreen@gs-lawfirm.com
www.gs-lawfirm.com

Criminal Tax New Haven CT: Former New Haven Tax Preparer is Sentenced

Criminal Tax New Haven CT: Former New Haven Tax Preparer is Sentenced

Jan 15, 2020

tax form and penJohn H. Durham, United States Attorney for the District of Connecticut, announced that DEVON WILLIAMS, 30, of Atlanta, Georgia, was sentenced today by U.S. District Judge Janet C. Hall in New Haven to eight months of imprisonment, followed by one year of supervised release, for preparing false tax returns.

According to court documents and statements made in court, Williams formerly owned and operated Perfect Preparers, LLC, a tax preparation business based in New Haven.  Between approximately 2014 and 2017, Williams prepared numerous federal tax returns for clients that contained inflated deductions, including false deductions for unreimbursed employee expenses, charitable donations, and mortgage interest. Some returns contained false Schedule C (sole proprietorship business) information.  Losses suffered by the IRS as a result of his fraud totaled at least $550,000.

Judge Hall ordered Williams to pay restitution of $550,000.

On October 3, 2019, Williams pleaded guilty to one count of aiding and assisting the preparation of a false tax return.

As a result of Williams’ fraudulent conduct, many of his clients’ filed tax returns will need to be amended.  Williams’ clients are required to resolve their own tax liability with the IRS.

Williams, who is released on a $150,000 bond, is required to report to prison on March 4, 2020.

This matter was investigated by the Internal Revenue Service – Criminal Investigation Division.  The case was prosecuted by Assistant U.S. Attorney Jennifer R. Laraia.

If you or someone you know has a criminal tax issue, or was victimized by Devon Williams, please contact us at (203) 285-8545 or by email at egreen@gs-lawfirm.com.

Eric L. Green, Esq.

Green & Sklarz LLC

One Audubon Street, 3rd Floor

New Haven, CT 06511

Ph. (203) 285-8545

Fax (203) 286-1311

egreen@gs-lawfirm.com

www.gs-lawfirm.com

Criminal Tax New Haven, CT: IRS Arrests Michael Avenatti at Hearing

Criminal Tax New Haven, CT: IRS Arrests Michael Avenatti at Hearing

Jan 15, 2020

We routinely represent taxpayers in civil and criminal tax cases.  We wanted to let everyone know that  IRS agents arrested embattled attorney Michael Avenatti in Los Angeles late Tuesday during a break in a hearing before the California State Bar, the U.S. attorney’s office confirmed , saying he allegedly violated the terms of his pretrial release on charges he embezzled client funds.

Michael Avenatti, famous for representing Adult Actress Stormy Daniels and had been positioning himself for a run for President, was arrested Tuesday, cutting short a hearing on whether his law license should be suspended while the California State Bar investigates disciplinary charges.

The hearing was on whether Avenatti’s law license should be suspended while the State Bar investigates disciplinary charges connected to allegations he stole a former client’s $1.6 million settlement payment. A spokesman for the U.S. Attorney’s Office for the Central District of California told the media that IRS agents arrested Avenatti for allegedly violating the terms of his pretrial release in the embezzlement case that is pending in California federal court. The documents related to the alleged violation are under seal, the spokesman said. Avenatti’s arrest comes the same day the attorney lost his bid to delay his upcoming trial in New York federal court on criminal charges he plotted to extort millions of dollars from Nike Inc. He is slated to go to trial Jan. 21. Tuesday’s proceedings at the State Bar were a continuation of a hearing from December to determine whether Avenatti’s law license should be suspended while the bar investigates bringing disciplinary charges in relation to accusations that he embezzled a $1.6 million settlement payment to his former client, Gregory Barela Jr. The California State Bar hearing was paused for nearly two hours on Tuesday while Avenatti attended the hearing in New York by telephone. After Avenatti finished that call, he took the stand in Los Angeles to testify that he has a hazy recollection of the details of the settlement agreement he negotiated on Barela’s behalf in an intellectual property dispute.

If you or someone you know has a criminal tax issue, or was victimized by Attorney Avenatti, please contact us at (203) 285-8545 or by email at egreen@gs-lawfirm.com.

Eric L. Green, Esq.

Green & Sklarz LLC

One Audubon Street, 3rd Floor

New Haven, CT 06511

Ph. (203) 285-8545

Fax (203) 286-1311

egreen@gs-lawfirm.com

www.gs-lawfirm.com

What are people saying about Eric Green's training?

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