Jeremy H. Temkin

September 17, 2009 | New York Law Journal

Jeremy H. Temkin, a principal in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, writes that a recent First Circuit decision has dealt a blow to the ability of taxpayers to maintain the confidentiality of candid assessments of their chances of success in litigation with the IRS. As a strong dissenting opinion points out, he notes. the First Circuit's en banc decision is at odds with the Second Circuit's decision in United States v. Adlman, and has far-reaching implications.

By Jeremy H. Temkin

13 minute read

March 17, 2005 | New York Law Journal

John J. Tigue Jr., a principal in Morvillo, Abramowitz, Grand, Iason & Silberberg, and Jeremy H. Temkin, also a principal in Morvillo, Abramowitz, write that over the past 12 months, the U.S. Court of Appeals for the Second Circuit has issued a limited number of tax decisions. While the court's opinion in Raymond v. United States addressed an issue of national import, those making less noise still have a significant impact and are worthy of review.

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

14 minute read

May 12, 2011 | New York Law Journal

In his Tax Litigation Issues column, Jeremy H. Temkin, a principal in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, writes on the IRS's efforts to reduce the $345 billion "tax gap" between what the government ought to be collecting in taxes and what it actually is collecting, focusing on the new tool of the Foreign Account Tax Compliance Act, which became law in 20101 and may have an even more significant impact on offshore banking than recent "carrot" and "stick" approaches.

By Jeremy H. Temkin

14 minute read

July 10, 2002 | New York Law Journal

C ONTINUING ITS trend toward fewer decisions in the tax field, the Supreme Court decided only three tax cases of note during its last term. All three cases addressed different facets of the Internal Revenue Service`s ability to collect taxes, ranging from assessment of Social Security taxes, application of the Bankruptcy Code to the discharge of debts and the availability of federal tax liens. In all three cases, the Court sided with the IRS, and in each case the Court gave an expansive reading to the IRS`s

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

11 minute read

September 20, 2007 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, write that last December, as part of its efforts to confront the "tax gap" resulting from the underpayment of taxes, Congress amended the whistleblower statute to increase the financial incentive for those willing to report tax fraud and to ensure that informants are treated fairly and consistently. The new law has not been fully implemented and it remains to be seen whether it wil succeed.

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

14 minute read

May 17, 2007 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, write that the IRS has adopted a policy of seeking tax accrual workpapers related to "listed transactions," which are transactions defined by the IRS as tax avoidance schemes. While many companies have complied with such requests, recently Textron Inc., an aerospace and defense contractor, has objected and the federal government has taken it to court over the issue.

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

12 minute read

January 30, 2006 | New Jersey Law Journal

An IRS settlement initiative allows taxpayers who engaged in certain identified transactions until Jan. 23, 2006 to file settlement forms with the service to resolve certain civil tax disputes with the service. These transactions include a wide-range of tax "schemes" including funds used for employee benefits, charitable remainder trusts, offsetting foreign currency option contracts, debt straddles, lease strips and certain abusive conservation easements.

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

10 minute read

May 15, 2008 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, write that in Wesley Snipes' famous role as a basketball hustler in the movie "White Men Can't Jump," his character tries to teach Woody Harrelson's character a life lesson about getting conned, saying "You either smoke, or you get smoked." In the recent courtroom battle between Mr. Snipes and the U.S. government, it was initially difficult to decide which side "got smoked." Both claimed victory - the government for three misdemeanor tax convictions and Mr. Snipes for two felony and three misdemeanor acquittals. At the end of April, however, Mr. Snipes was sentenced to three years in prison, thus giving greater credence to the government's assertion that it "won" the case.

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

15 minute read

September 16, 2004 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason & Silberberg, write that snce the days of Al Capone, tax laws have provided a vehicle for prosecuting those whose more pernicious crimes are harder to prove. Now, two decisions from earlier this summer may limit the ability of local prosecutors to bring tax charges against defendants.

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

13 minute read

March 16, 2006 | New York Law Journal

John J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason & Silberberg, write that the globalization of the economy extends to criminal activity, which is becoming more complex and international in scope. One result of this phenomenon is increased cooperation between the United States and foreign governments in gathering evidence and sharing information.

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

13 minute read