Tuesday, January 28, 2025

Two Recent Tax Crimes Cases Involving Bitcoin

Trump fires 17 independent inspectors general at federal agencies, source says


Two Recent Tax Crimes Cases Involving Bitcoin 

In my immediately preceding post (2 days ago) on the indictment of Tom Goldstein, I mentioned that among the allegations were allegations that Goldstein had not properly reported his cryptocurrency transactions. I said that I would post some other recent items involving cryptocurrency. These recent items involve Bitcoin, perhaps the most prominent type of cryptocurrency. Goldstein’s indictment does not specify the type of cryptocurrency he allegedly used.




New Information for Tax Conspiracy and Related Credit Suisse (through Successor UBS) Initiatives Re Violation of 2014 Plea Agreement 

In United States v. Rosenberg (S.D. FL No. 1:25-cr-20005, CL Dkt. Sheet here), the Government filed an Information with Trial Attorney Certificate, here, charging Gilda Beth Rosenberg (aka Gilda Rosemberg Percezek) with one count of conspiracy to defraud and commit offenses (i.e., both a defraud and an offense conspiracy in one count). Except for the large amounts involved, the allegations are not unusual for U.S. taxpayers who employed Swiss financial institutions to avoid their U.S. tax reporting and paying obligations. That the filing is an information with an attached Trial Attorney Certificate indicating that 0 days of trial is expected suggests that a plea deal has been reached, will be filed with the district court soon, and will be processed to sentencing in due course.


Hitler Pardoned His Goons Too Trump’s Actions' Parallels with Germany 1935


Tom Goldstein--SCOTUSblog founder, Prominent Supreme Court Advocate, and High-Stakes Gambler--Indicted for Tax and Related Crimes and False Statements to Mortgage Lenders


Updates on Developments in IRS Penalty Administration and Voluntary Disclosure 

I post here links to earlier posts on my Federal Tax Procedure Blog about the IRS’s Voluntary Disclosure Practice (“VDP”). ABA Tax Section Comments on VDP Disclosure Form 14457, Voluntary Disclosure Practice Preclearance and Application (1/5/25), here; and IRS Voluntary Disclosure Practice (VDP) Requires Taxpayer Admit Criminal Willfulness(11/29/24; 1/5/25), here.

Also, I have just recently learned that, in the National Taxpayer Advocate’s Annual Report to Congress 2024here, the NTA discusses two of 10 Most Serious Problems Encountered by Taxpayers that relate to tax administration of the type addressed in this blog (Federal Tax Crimes) and the companion blog (Federal Tax Procedure). Items 9 and 10 are, respectively:

9. Civil Penalty Administration (pdf 16 pages), here; and

10. Criminal Voluntary Disclosure (pdf 17 pages), here.