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September 10, 2009 - Phil Hodgen

The IRS nails a lawyer and an accountant for offshore tax stuff

The foreign account amnesty is winding down to the last days. If you’re wondering about the payoff for the IRS, look no further. Here’s an example. An attorney and an accountant in Arizona have been indicted for setting up offshore tax structures.

This is unrelated to any of my pending cases. But let me guess how these guys were fingered. One of their clients got hinky, and decided to apply for the amnesty. As part of the full disclosure done by the taxpayer, the lawyer and the accountant were identified as assisting in setting up the structure.

Bad news arrives for the attorney and accountant in the form of an indictment from the Department of Justice.

This is the avowed intent of the IRS. They are looking for the people who helped U.S. taxpayers evade taxes. Bankers, lawyers, accountants.

Here’s the collateral damage. All of the other taxpayers represented by these two guys are now at risk. They’ll have audit flags on their accounts and will be ineligible for the amnesty if they apply. And they’ll get a letter if they don’t apply for the amnesty. They’re cooked.

Moral of the story: (1) don’t do manky stuff; (2) don’t deal with manky people; and most important (3) if you have violated number 1 or number 2, you are now in a race to see whether you can get your foot in the door before the IRS flags you because your name is now associated with manky people.

Voluntary Disclosure