Jeremy H. Temkin

March 12, 2009 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, discuss a closely-watched case, recently reviewed by the First Circuit, that broadened the scope of what may be protected as work product but left open the issue of whether disclosure of work product to independent auditors constitutes a waiver.

By John J. Tigue Jr. and Jeremy H. Temkin

11 minute read

July 16, 2009 | New York Law Journal

Jeremy H. Temkin, a principal in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, reviews the relationship between the Fifth Amendment and the U.S. tax system's reliance on self-reporting by tax payers, and a recent Second Circuit decision where the appellant argued that his failure to file tax returns should be excused because, in light of the ongoing investigation into his tax liability and the validity of losses claimed from earlier tax shelter transactions, the very filing of returns for the years in question would tend to incriminate him.

By Jeremy H. Temkin

13 minute read

May 14, 2003 | New York Law Journal

By John J. Tigue Jr. And Jeremy H. Temkin

7 minute read

January 18, 2008 | Law.com

Federal criminal cases frequently are brought against multiple defendants facing multiple charges, some of which are common to all defendants and some of which are not. Federal Rule of Criminal Procedure 8 dictates the proper joinder of offenses and defendants in an indictment. Attorneys John J. Tigue Jr. and Jeremy H. Temkin discuss a recent 2nd Circuit case that helps clarify the application of Rule 8 to indictments charging both tax and nontax crimes.

By John J. Tigue Jr. and Jeremy H. Temkin

12 minute read

July 19, 2007 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals at Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, write that the Treasury and IRS recently issued two notices regarding the types of financial penalties that can be imposed on tax professionals.

By John J. Tigue Jr. and Jeremy H. Temkin

12 minute read

July 08, 2010 | New York Law Journal

In his Tax Litigation Issues column, Jeremy H. Temkin, a principal in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, writes that after years of failed efforts, a provision codifying the economic substance doctrine was included in the Health Care and Education Reconciliation Act of 2010. While its full impact will not be felt for years, this long-anticipated move will likely affect tax shelter litigation for years to come.

By Jeremy H. Temkin

16 minute read

July 21, 2005 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason & Silberberg, write that the U.S. Supreme Court issued three tax-related opinions this past term.

By John J. Tigue Jr. and Jeremy H. Temkin

14 minute read

July 19, 2006 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason & Silberberg, write that major executives of public companies soon may find themselves in need of new accountants to handle their personal tax services. The SEC has recently adopted rules prohibiting auditors of public companies from performing personal tax services for certain executives, which will likely result in significant shuffling of the client lists of many accounting firms in the coming months.

By John J. Tigue Jr. and Jeremy H. Temkin

12 minute read

January 17, 2008 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, write that a Second Circuit decision offers an important reminder of the careful analysis necessary to evaluate the joinder of tax and nontax counts. While the government commonly tries to expand indictments, the recent case demonstrates the limits of joinder, even where the misjoined counts share certain commonalities.

By John J. Tigue Jr. and Jeremy H. Temkin

12 minute read

September 18, 2008 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, members of Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, analyze two recent rulings: one centering on IRS summonses to gather information in connection with civil examinations and criminal investigations; and the other focusing on the government's obligation to prove willfulness, the existence of a tax deficiency and an affirmative act of evasion.

By John J. Tigue Jr. and Jeremy H. Temkin

10 minute read