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Does the IRS charge taxpayers criminally for filing a false Form 433?

Yes The IRS may charge a taxpayer with any number of crimes for filing a false 433 including Tax Evasion Evasion of Payment under IRC 7201 Filing a false document with the IRS under IRC 7206 perjury and wire fraud of the 433 was faxed or mail fraud if it was sent to the IRS through the mail See also United States v Brimberry Janice A 961 F2d 1286 1992 In United States v Brimberry the Seventh Circuit affirmed Janice Brimberrys convictions and 33month sentence for making false statements to the IRS and attempted tax evasion arising from her role in concealing assets tied to a large embezzlement scheme The court held that the trial judge had no duty to affirmatively inquire into Brimberrys decision not to testify and properly rejected a jury instruction on goodfaith reliance on an accountant because there was no evidence of full disclosure or reliance on advice to conceal assets Substantial evidence showed Brimberry willfully hid significant assets through filing a false 433 and sham transactions The court also upheld sentencing based on the full 7 million tax loss concluding the Guidelines properly measure loss by the total tax owed not the value of recoverable assets

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