Category Archives: criminal tax law

According to DoJ, the Internal Revenue Service provided the regular quarterly update to the Strategic Operating Plan, outlining key milestones in criminal investigations, improvements to taxpayer services and advancements in digital modernization that have transformed agency operations while protecting billions of taxpayer dollars.

The IRS has now recovered $4.7 billion from new initiatives underway. This includes: 

• More than $1.3 billion from high-income, high-wealth individuals who have not paid overdue tax debt or filed tax returns, 
• $2.9 billion related to IRS Criminal Investigation work into tax and financial crimes, including drug trafficking, cybercrime and terrorist financing, and 
• $475 million in proceeds from criminal and civil cases attributable to whistleblower information.

The IRS also announced new results from the focus on high-income non-filers who have not filed taxes since 2017. 

The IRS Has Now Collected An Initial $292 Million
From More Than 28,000 Non-Filers, An Increase
of $120 Million Since September 2024.

These are cases where IRS has received third party information, such as through Forms W-2 and 1099s, indicating these people received income between $400,000 and $1 million or more than $1 million, but failed to file a tax return. The non-filer program ran sporadically since 2016 due to severe budget and staff limitations that did not allow these cases to be pursued. With additional funding, the IRS had the capacity to resume this core tax administration work earlier this year.

“The IRS continues to show dramatic progress on a wide array of the agency’s transformation efforts, producing real-world improvements to help taxpayers and businesses while also taking important steps in the law-enforcement and compliance arena to protect billions from ongoing schemes, ensure high-income individuals file returns and pay their taxes and penalties, and battle everything from terrorist financing to drug traffickers,” said IRS Commissioner Danny Werfel.

Assistance from whistleblowers

Whistleblowers continue to provide valuable contributions in both criminal and civil cases. Whistleblower information has led to successful criminal investigations, prosecutions and the collection of tax, fines, penalties, interest and other amounts. 

In FY24, the IRS paid awards totaling $123.5 million to whistleblowers for aiding in the collection of $474.7 million in proceeds on cases that included unreported/underreported income, hidden offshore assets, overstated deductions, general allegations of tax fraud and abusive international transactions.

Have an IRS Tax Problem?

     Contact the Tax Lawyers at

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

Read more at: Tax Times blog

On September 13, 2004, we posted Early Bitcoin Investor Pleads Guilty to Filing Tax Return that Falsely Reported His Cryptocurrency Gains, where we discussed the first public indictment of an individual who underreported the capital gains from a nearly $4 million legal sale of bitcoin and his Guilty plea on   September 12, 2024. 

Now according to Law360, Frank Richard Ahlgren III was sentenced to two years in federal prison On December 12, 2024. He was also ordered by a Texas federal court to pay more than $1 million in restitution to the Internal Revenue Service for the lost tax dollars.

The Prison Sentence Is Just Shy of The 27 Months Prosecutors Requested When They Argued In A Sentencing Memo That It Would Serve As A Needed Warning To Virtual Currency
Users It Said Were "Watching This Case."

Ahlgren was indicted in February and accused of making false returns for 2017 through 2019 and violating structuring laws. He was held without bail as a flight risk, and in September he pled guilty to filing a false return for 2017. In October of that year he sold 640 bitcoins for $5,800 each, reaping gains after buying the bitcoins two years earlier for less than $500 each.

Instead of reporting the true gains on his returns, he claimed he had bought the bitcoins in 2015 for much higher prices. While the highest amount any of the bitcoins traded for in 2015 was $495, Ahlgren claimed he had paid up to $9,400, prosecutors said in a sentencing memo.

Prosecutors also accused Ahlgren of selling bitcoins for $650,000 in 2018 and 2019 and failing to report the sales at all. From 2017 through 2019, he either underreported or didn't report the sale of $4 million worth of bitcoins, the DOJ said. He took sophisticated steps to hide the transactions on the bitcoin blockchain, or public ledger, including disguising his identity using mixers and meeting someone in person to exchange bitcoins for cash.

Ahlgren, who blogged about the virtual currency, knew how to hide transactions on bitcoin's blockchain and exploited the anonymity the system provides, prosecutors said.

"Ahlgren will serve time because he believed his cryptocurrency transactions were untraceable," Acting Special Agent in Charge Lucy Tan of an IRS criminal investigation unit in Texas said in a statement.

Stuart M. Goldberg, acting deputy assistant attorney general of the DOJ's Tax Division, said Ahlgren had earned his sentence when he lied to his accountant about the gains and failed to pay his taxes. 

Have an Unreported Crypto Currency?

 Like Your Freedom? 

  Contact the Tax Lawyers at

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

Read more at: Tax Times blog

In an Alert entitled "Impact of Ongoing Litigation – Deadlines Stay – Voluntary Submissions Only FinCEN has stated that:

In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.

The Corporate Transparency Act (CTA) plays a vital role in protecting the U.S. and international financial systems, as well as people across the country, from illicit finance threats like terrorist financing, drug trafficking, and money laundering.  The CTA levels the playing field for tens of millions of law-abiding small businesses across the United States and makes it harder for bad actors to exploit loopholes in order to gain an unfair advantage.

On Tuesday, December 3, 2024, in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.), a federal district court in the Eastern District of Texas, Sherman Division, issued an order granting a nationwide preliminary injunction that: (1) enjoins the CTA, including enforcement of that statute and regulations implementing its beneficial ownership information reporting requirements, and, specifically, (2) stays all deadlines to comply with the CTA’s reporting requirements. The Department of Justice, on behalf of the Department of the Treasury, filed a Notice of Appeal on December 5, 2024.

Texas Top Cop Shop is only one of several cases in which plaintiffs have challenged the CTA that are pending before courts around the country. Several district courts have denied requests to enjoin the CTA, ruling in favor of the Department of the Treasury. The government continues to believe—consistent with the conclusions of the U.S. District Courts for the Eastern District of Virginia and the District of Oregon—that the CTA is constitutional.

While this litigation is ongoing, FinCEN will comply with the order issued by the U.S. District Court for the Eastern District of Texas for as long as it remains in effect. Therefore, reporting companies are not currently required to file their beneficial ownership information with FinCEN and will not be subject to liability if they fail to do so while the preliminary injunction remains in effect. Nevertheless, reporting companies may continue to voluntarily submit beneficial ownership information reports.

Need Help Filing Your BOI Report?

     Contact the Tax Lawyers at

Marini & Associates, P.A. 

Read more at: Tax Times blog

In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.

Notice of BOI Filing Page The Corporate Transparency Act (CTA) plays a vital role in protecting the U.S. and international financial systems, as well as people across the country, from illicit finance threats like terrorist financing, drug trafficking, and money laundering.  The CTA levels the playing field for tens of millions of law-abiding small businesses across the United States and makes it harder for bad actors to exploit loopholes in order to gain an unfair advantage. On Tuesday, December 3, 2024, in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.), a federal district court in the Eastern District of Texas, Sherman Division, issued an order granting a nationwide preliminary injunction that: (1) enjoins the CTA, including enforcement of that statute and regulations implementing its beneficial ownership information reporting requirements, and, specifically, (2) stays all deadlines to comply with the CTA’s reporting requirements. The Department of Justice, on behalf of the Department of the Treasury, filed a Notice of Appeal on December 5, 2024. Texas Top Cop Shop is only one of several cases in which plaintiffs have challenged the CTA that are pending before courts around the country. Several district courts have denied requests to enjoin the CTA, ruling in favor of the Department of the Treasury. The government continues to believe—consistent with the conclusions of the U.S. District Courts for the Eastern District of Virginia and the District of Oregon—that the CTA is constitutional. While this litigation is ongoing, FinCEN will comply with the order issued by the U.S. District Court for the Eastern District of Texas for as long as it remains in effect. Therefore, reporting companies are not currently required to file their beneficial ownership information with FinCEN and will not be subject to liability if they fail to do so while the preliminary injunction remains in effect. Nevertheless, reporting companies may continue to voluntarily submit beneficial ownership information reports. Need Help Filing Your BOI Report?      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)

Read more at: Tax Times blog