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Article • January 1, 2001 • from P&J January, 2001
U.S. v. Simonelli, No. 00-1326 (1st Cir.) (237 F.3d 19) (January 19, 2001) (Judge Sandra L. Lynch) by Here the Court rejected the defendant's contention that Apprendi requires the jury to determined the amount of the tax liability in a tax fraud prosecution - "at least" because the defendant's sentence …
Article • November 1, 1998 • from P&J November, 1998
U.S. v. Silkman, No. 97-3888 (8th Cir.) (156 F.3d 833) (September 16, 1998) (Judge James B. Loken) by This is a rare tax evasion case which the defendant won, largely because he was able to convince the Court of the inherent unfairness of the IRS's practice of issuing "naked assessments." …
Article • December 1, 1997 • from P&J December, 1997
U.S. v. Tenzer, No. 96-1653 (2nd Cir.) (127 F.3d 222) (September 19, 1997) (Judge Roger J. Miner) by Here the Court held that one of the key components of the Voluntary Disclosure Policy was the requirement that the taxpayer make bona fide arrangements to pay his tax liability - and …
Article • January 1, 1994
Lord v. Kelley, No. Civ. A No. 63-932 (D.Mass.) (240 F.Supp. 167) (April 13, 2065) (Judge Charles Edward Jr. Wyzanski) by Despite finding that an IRS agent had defied a court order in using records that had been obtained in an unlawful search and seizure, the Court held that the …