Thursday, March 16, 2017

Head Coaches: Contempt on Foreign Bank Account Records Subpoena

“Leadership is a matter of having people look at you and gain confidence…If you’re in control, they’re in control.”

—Tom Landry, Head Coach Dallas Cowboys (1960-88)

Following a 51-0 loss to Notre Dame in 1966. "I told my team it doesn't matter. There are 750 million people in China who don't even know this game was played. The next day, a guy called me from China and asked, 'What happened, Coach?'
  ~ Doug Williams

The role of the head coach begins with setting a standard of competence. You have to exhibit a strong working knowledge of the game. The head coach must be able to function effectively and decisively in the most stressful situations. And the head coach must demonstrate resourcefulness—in particular, he is responsible for designing a system of football that is not simplistic. The head coach’s system should never reduce the game to the point where he can blame his players for success or failure simply because they did not physically overwhelm the opponents.
Successful coaches realize that winning teams are not run by single individuals who dominate the scene and reduce the rest of the group to marionettes. Winning teams are more like open forums in which
everyone participates in the decision-making process, coaches and players alike, until the decision is made. Others must know who is in command, but a head coach must behave democratically. Then, once a decision is made, the team must be motivated to go ahead and execute it.
What does it take to create a decision-making process in which people feel they can participate?
To Build a Winning Team: An Interview with Head Coach Bill Walsh 

“The achievements of an organization are the results of the combined effort of each individual.”
“People who work together will win, whether it be against complex football defenses, or the problems of modern society.”
“Individual commitment to a group effort – that is what makes a team work, a company work, a society work, a civilization work.”
 Vince Lombardi on Success and Failure
Good coaches take responsibility for their team's failures and give their team and athletes full responsibility for successes  (quotes)
Bad coaches blame their athletes for losses and take the credit for the team's successes
You're NOT a good coach when you allow players on your team to scape-goat and/or demean each other:

Tony Dungy said in his book, “The higher up the coaching ladder you go, the further you get from actual coaching.” He said that as a head coach he missed the individual attention and coaching he could give to his players because he was involved in so many other duties. A head coach, to me, is like the General of an army. His job is to plan and direct. He’s not in the muck and filth of war. Instead, he’s sort of a figurehead who has seen it and done it all and leads from the front because of that. He’s skilled in combat tactics and military philosophies. He sees the game from a different perspective than everyone else and has to be the leader, the directive force within the group. Some head coaches will call plays, and again, that adds another level of duties to his already stacked pile. It also requires that he has the additional skills to be a competent playcaller.
The Failure of Head Coaches via BC

News from the Profession. Man, This EY Auditor Made Some Bad Choices (Caleb Newquist, Going Concern)

Third Circuit Affirms Contempt on Foreign Bank Account Records Subpoena

Jack Townsend previously reported on United States v. Chabot, 793 F.3d 338 (3d Cir 2015), here, an almost garden-variety case enforcing a grand jury subpoena for production of foreign bank account records.  See Third Circuit Applies Required Records Doctrine to Require Taxpayers to Respond to Compulsory Process About Foreign Bank Account (Federal Tax Crimes Blog 7/18/15), here.  Yesterday, the Third Circuit issued another opinion after Eli Chabot was held in contempt on remand for failure to comply.  United States v. Chabot, 2017 U.S. App. LEXIS 4355 (3d Cir. 2017) (nonprecedential), here.

Taxpayer with Israeli Bank Accounts Sentenced to 24 Months 

DOJ Tax announced here the sentencing of Masud Sarshar.  (I had previously posted on his information and plea in an earlier blog entry Another Plea to Offshore Account Tax Crimes (Federal Tax Crimes Blog 8/1/16), here.)  The key information from the current news release regarding the sentencing is:
A Los Angeles, California businessman was sentenced to 24 months in prison today for hiding more than $23.5 million in offshore bank accounts * * * *
While respecting our history and maintaining a strong vision, The Tax Institute will continue to evolve and will continue serving the contemporary needs of members for many years to come.
The evolution of The Tax Institute

 Commissioner’s address to the Tax Institute National Convention 2017

The ATO just accused you of being a bigger tax problem than Apple