Recently by Lawrence S. Horn
Tax
Home Concrete & Supply Redux? Expansive Interpretation of the “Fraud” Exception to the Three-Year Statute of Limitations
As a general a rule, the Internal Revenue Service has three years from the date a tax return is filed to propose adjustments to that return or lose the right to do so.[1] However, the Internal Revenue Code also provides exceptions under which the three-year period can be extended. The exceptions...
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Caveat Interests In Foreign Accounts
Editor: Please describe your practice at Sills Cummis & Gross. What is your background with the Justice Department? Horn: I was an Assistant United States Attorney in the District of New Jersey Attorney’s office for seven years in the mid-1970s. An Assistant U.S. Attorney...
Read More"Tax Amnesty" Is Still An Option: IRS Offers A "Second Chance" To Taxpayers With Undeclared Foreign Accounts And Holdings
On January 26, 2011, the IRS "moved East" in its attack on foreign banks and their U.S. customers with undisclosed offshore accounts. The Department of Justice indicted Vaibhave Dahake, an Indian-American businessman in New Jersey, for conspiring with several bankers at an "...
Read MorePending Cases In The U.S. Tax Court To Test IRS Transferee Liability Position On "Midco" Transactions
Beginning in the late 1990s, after a period in which it had focused on being more "customer oriented" while audit rates dropped radically, IRS woke up to the fact that major legal and accounting firms were marketing various tax savings strategies to taxpayers and earning substantial fees for their...
Read MoreSwiss Banks No Longer A Safe Haven?
Editor:Larry Horn and Rich Sapinski, you have extensive experience both on the prosecution and defense sides of the criminal tax spectrum. Would you share some of your backgrounds with our readers? Horn: After graduating from law school, shortly thereafter I became an Assistant United States...
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