May 14, 2009 | New York Law Journal
Tax Litigation IssuesJeremy H. Temkin, a principal in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, discusses recent guidance issued by the IRS regarding civil penalties it will impose on taxpayers who make "voluntary disclosure" of their offshore accounts. Although the reduced penalties are still substantial, they pale in comparison to those that could otherwise be imposed.
By Jeremy H. Temkin
13 minute read
September 14, 2005 | New York Law Journal
Tax Litigation IssuesJohn J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason & Silberberg, write that while the number of tax protestors in recent years has increased, it is unlikely that the IRS will be discouraged in its pursuit of these individuals or in debunking their claims.
By John J. Tigue Jr. and Jeremy H. Temkin
13 minute read
May 15, 2002 | New York Law Journal
Tax Litigation IssuesO ur tax system is overwhelmingly dependent on self-reporting. It relies on a healthy mix of taxpayer honesty and fear of the consequences of being caught cheating. Effective and even-handed enforcement of the tax laws is a critical component of this system. Thus, "fair and uniform application" of enforcement mechanisms is one of the Internal Revenue Service`s primary strategic goals following passage of IRS Restructuring and Reform Act of 1998 (the "1998 Act"). But the IRS now finds itself battling the cha
By John J. Tigue Jr. And Jeremy H. Temkin
15 minute read
November 15, 2007 | New York Law Journal
Tax Litigation IssuesJohn J. Tigue Jr. and Jeremy H. Temkin, principals in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, write that, inevitably, some IRS civil audits grow into criminal investigations. IRS policies instruct revenue agents to cease a civil audit when they become aware of criminal wrongdoing, but two recent cases demonstrate that the law is far from clear.
By John J. Tigue Jr. and Jeremy H. Temkin
14 minute read
January 14, 2010 | New York Law Journal
Tax Litigation IssuesJeremy H. Temkin, a principal in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, writes that the government's aggressive pursuit of all avenues used to conceal United States income offshore is clearly continuing, and the IRS's most recent tax initiative has resulted in a large number of voluntary disclosures by taxpayers holding previously undisclosed offshore accounts.
By Jeremy H. Temkin
14 minute read
May 19, 2010 | New York Law Journal
The State of IRS Enforcement EffortsIn his Tax Litigation Issues column, Jeremy H. Temkin, a principal in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, writes that it would seem that the Obama administration's focus on offshore accountholders is firmly in place, and we can expect to see increased focus on eliminating the ability of large corporations to avoid their tax obligations.
By Jeremy H. Temkin
11 minute read
March 27, 2003 | New York Law Journal
Tax Litigation IssuesBy John J. Tigue Jr. And Jeremy H. Temkin
12 minute read
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