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Monthly Archives: October 2025

Dual Citizen Must Ordered to Pay $5.3M FBAR Penalty

According to Law360, a dual citizen Individual was ordered to pay $5.3 million in penalties and interest for willful failure to report a Swiss bank account, according to a judgment a New York federal judge issued on January 31, 2024.

U.S. District Judge granted the government's motion for default judgment against Vladimir Mrvic, which the U.S. government said it filed after Mrvic failed to respond to repeated attempts to contact him. 


The Internal Revenue Service In 2019 Assessed A Penalty Of
$4.1 Million, Half The Amount In The Account In 2012, A Year For Which He Failed To Report, According To Court Documents.

As of late September, Mrvic owed $5.3 million, including $161,500 in interest and $969,000 in nonpayment penalties, the government said.

Mrvic opened an account with Swiss bank Julius Baer & Co. Ltd. in 2005 on behalf of Beaucastel Management Corp., of which he was the beneficial owner, according to court documents.

Two years after the Julius Baer account's value peaked at $11.77 million in September 2007, the Swiss bank informed Beaucastel that it needed an IRS W-9 form on file, the government said.

Rather than provide that information, the government said, Mrvic closed Beaucastel's account at Julius Baer and then transferred $5.47 million to another Swiss bank, Banque Privee Edmond de Rothschild SA. He used the funds for an "extravagant lifestyle," including purchases of condos and villas in St. Marten and Hong Kong, according to the government.

Mrvic indicated on his 2011 tax year forms that he had a foreign account, but he said he didn't need to file a form reporting it because it totaled less than $10,000, according to court documents. Mrvic deliberately misled authorities on this point, the government said.

 Do You Have Undeclared Offshore Income?

 
Want to Know if the OVDP Program is Right for You? 
Contact the Tax Lawyers at 
Marini & Associates, P.A.   
for a FREE Tax Consultation contact us at:
or Toll Free at 888-8TaxAid (888) 882-9243




Read more at: Tax Times blog

41-Month Prison Sentence Highlights Risks of Concealing Offshore Earnings

According to DoJ, a Texas man was sentenced today to 41 months in prison for evading his taxes by not reporting income he earned while working overseas.

According to court documents and statements made in court, from 2013 to 2018, Peter Joseph Tignini, formerly of Cypress, Texas, worked in the United Arab Emirates and Qatar, earning over $4,750,000 in income. For tax years 2013 through 2017, Tignini filed false tax returns that claimed that his income was only approximately $100,000 each year. The amount Tignini reported each year was near or below the amount that U.S. citizens who live and work abroad for most of a year can exclude from their taxable income on their U.S. tax return. Tignini did not file a return for 2018. As a result, Tignini caused a tax loss to the IRS of $1,169,348.

Following an interview with federal law enforcement, Tignini altered his employment contract and payroll documents to make it appear that his former employer, not Tignini himself, was responsible for failing to report the income and pay the tax. Tignini then caused his attorneys to provide the false documents to the Justice Department’s Tax Division and the IRS. After investigators asked a witness about the online program Tignini used to create the phony documents, Tignini attempted to delete the documents from his account.

In addition to the term of imprisonment, U.S. District Court Judge George C. Hanks ordered Tignini to serve three years of supervised release and to pay $1,169,348.60 in restitution to the United States.

 Do You Have Undeclared Offshore Income?

 
Want to Know if the OVDP Program is Right for You? 
Contact the Tax Lawyers at 
Marini & Associates, P.A.   
for a FREE Tax Consultation contact us at:
or Toll Free at 888-8TaxAid (888) 882-9243



Read more at: Tax Times blog

Recent IRS Enforcement Against Ghost Tax Preparers (No Signature As Preparer)

The IRS remains committed to protecting taxpayers by rigorously pursing and prosecuting unethical or fraudulent tax preparers. Recent enforcement actions highlight how the IRS is holding fraudulent tax preparers accountable and are a critical part of maintaining integrity and public trust in the tax system. IRS Criminal Investigation (IRS-CI) is the law enforcement arm of the IRS responsible for conducting financial crime investigations, including tax fraud. IRS-CI investigated the following schemes generating over $1 million in fraudulent tax refunds.

In August 2025, Kim Brown, who operated a “ghost” tax preparation business in Augusta, GA, was sentenced to 22 months in federal prison and ordered to pay $541,912 in restitution for defrauding the IRS. Brown operated as a “ghost” preparer because she failed to identify herself as a paid preparer on the tax returns that she prepared and filed for her clients. As a “ghost” preparer, Brown fabricated income to qualify her clients for tax credits, claimed fake deductions to boost the size of the refund, and charged clients a fee based on a percentage of the tax refund.

“Not signing off on a tax return is just one of the signs someone is acting as a ghost preparer,” said Special Agent in Charge Demetrius Hardeman, IRS CI, Atlanta Field Office. “Today’s sentencing of Kim Brown is an example of IRS Criminal Investigation special agents working diligently to protect taxpayers from dishonest tax preparers and a notification to the public of just one scheme utilized by ghost tax preparers.”

On September 25, 2025, Allen Brown, who also operated a “ghost” tax preparation business in Augusta, was sentenced to 46 months in federal prison and ordered to pay $1,003,631 in restitution for defrauding the IRS. Court documents state that in 2022 and 2023, Brown and several individuals operated a “ghost” tax preparation business by failing identify himself as a paid preparer on the federal income tax returns that he prepared and filed for his clients. As a “ghost” preparer, Brown fabricated income to qualify his clients for tax credits, claimed fake deductions to boost the size of the refund, and charged clients a fee based on a percentage of the tax refund. Brown and other “ghost” preparers who worked with him falsified 63 federal income tax returns for clients.

“Every year around tax season, ghost tax preparers like Allen Brown and other unscrupulous preparers open up shop to take advantage of unsuspecting taxpayers by convincing them into taking credits and benefits for which they don’t qualify,” said Hardeman. “IRS Criminal Investigation special agents are working to protect taxpayers from these unethical tax preparers by investigating and holding them accountable.”

 Have an IRS Tax Problem?


     Contact the Tax Lawyers at

Marini & Associates, P.A. 


for a FREE Tax HELP Contact us at:
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or 
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Read more at: Tax Times blog

Chaos & Delays: What the IRS Shutdown Means for Taxpayers in Fall 2025

With nearly half of IRS employees furloughed and agency operations shuttered, the 2025 government shutdown is sending shockwaves through the tax world. From October 8th onward, the IRS has moved to an emergency footing, leaving over 34,000 staff at home with only the barest skeleton crew to handle critical functions tied to tax season and new legislative priorities.

With nearly half of IRS employees furloughed and agency operations shuttered, the 2025 government shutdown is sending shockwaves through the tax world. From October 8th onward, the IRS has moved to an emergency footing, leaving over 34,000 staff at home with only the barest skeleton crew to handle critical functions tied to tax season and new legislative priorities.

If you’re preparing to file tax returns, waiting on a refund, or seeking IRS support for complex matters, expect massive delays and plan ahead. E-filing and automated payments remain live for now, but almost every other service from live taxpayer help to paper return processing to Taxpayer Advocate support is suspended. Audits, appeals, and most compliance routines are now on pause.

Filing deadlines haven’t budged, interest and penalties continue to accrue, and most taxpayers will find it difficult (if not impossible) to reach IRS representatives for urgent issues. The IRS workforce that remains is focused on essential processing and new projects arising from recent legislation—meaning normal tax operations simply aren’t happening.

What’s next? Until Congress passes a funding bill, anticipate longer waits, slower refunds, and an ominous backlog that could stretch well into next year’s filing season. Tax law hasn’t changed, but how quickly the IRS can serve taxpayers most certainly has. Be proactive: file promptly, document everything, and consult a tax professional for guidance if you’re up against deadlines or need compliance support.

When Washington gridlock meets IRS shutdown, America’s taxpayers are the ones left waiting. Stay informed and be ready for a bumpy ride as this crisis unfolds.

 Have an IRS Tax Problem?


     Contact the Tax Lawyers at

Marini & Associates, P.A. 


for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or 
Toll Free at 888 8TAXAID (888-882-9243)





Sources:

1.       https://www.irs.gov/newsroom/irs-employee-emergency-news         

2.      https://www.reuters.com/world/irs-furlough-34000-employees-due-us-government-shutdown-2025-10-08/ 

3.      https://www.newsweek.com/irs-furlough-staff-what-means-for-taxes-10851422  

4.      https://www.cnbc.com/2025/10/08/irs-furloughs-workers-government-shutdown.html

5.       https://tax.thomsonreuters.com/news/irs-furloughs-begin/      

6.      https://www.nbcnews.com/business/taxes/irs-furloughs-thousands-employees-shutdown-rcna236503  

7.       https://www.cnn.com/2025/10/09/politics/irs-furloughs-government-shutdown  

8.      https://www.thetaxadviser.com/news/2025/oct/irs-furloughs-staff-closes-most-operations-as-shutdown-enters-second-week/ 

9.      https://www.politico.com/live-updates/2025/10/08/congress/irs-begins-furloughing-employees-00597834

10.   https://www.govexec.com/workforce/2025/10/more-employees-set-receive-furlough-notices-shutdown-drags/408629/

11.    https://www.forbes.com/sites/kellyphillipserb/2025/10/08/irs-halts-most-taxpayer-services-as-it-furloughs-nearly-half-its-workers/

12.   https://blog.abgi-usa.com/articles/irs-shutdown-impact-on-tax-incentives

13.   https://www.psu.edu/news/research/story/ask-expert-what-happens-during-government-shutdown

14.   https://blog.taxact.com/government-shutdown-irs-tax-updates/

15.    https://www.plansponsor.com/irs-halts-operations-furloughs-employees-as-shutdown-drags-on/

16.   https://windhambrannon.com/blog/what-taxpayers-should-expect-during-a-full-irs-shutdown/

17.    https://www.nteu.org/blog/2025/10/08/IRSShutdownStatement

18.   https://blog.tax990.com/2024/01/24/irs-shutdown-prompts-a-need-to-paper-file-forms-990-t-1120-pol-and-8868/

19.   https://www.crfb.org/papers/government-shutdowns-qa-everything-you-should-know


Read more at: Tax Times blog

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