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Category Archives: criminal tax law

Supreme Court Limits Nationwide Injunctions: What You Need to Know & Impact on IRS Firings

In a decision with major implications for American law and government, the Supreme Court recently put a sharp check on the power of federal judges to issue nationwide injunctions. The ruling, handed down in June 2025, didn’t ban these sweeping orders outright, but it made clear they should be used only in the rarest of circumstances. Here’s what happened and what it means for you.

The Basics: What Are Nationwide Injunctions?
A nationwide injunction is a court order that stops the federal government from enforcing a law, policy, or executive order anywhere in the United States, not just for the people who brought the lawsuit, but for everyone. Over the past several years, these injunctions have become a go-to tool for groups opposing presidential or federal agency actions, allowing a single judge to put the brakes on major policy changes across the entire country.

The Case That Sparked the Change
The Supreme Court’s ruling in 
Trump v. CASA came in response to lawsuits challenging a Trump-era executive order on birthright citizenship. The lower courts had blocked the order nationwide, but the Supreme Court didn’t rule on the constitutionality of the policy itself. Instead, it focused on whether judges have the authority to issue such broad injunctions.

What the Court Decided

The Supreme Court, in a 6-3 decision, said that nationwide injunctions “likely exceed the equitable authority” given to federal courts by Congress. 

In Most Cases, Judges Should Only Grant Relief To The
Actual Plaintiffs In A Case, Not To Everyone In The Country.

The Court left open the possibility of a broader injunction if it’s absolutely necessary to provide “complete relief” to the plaintiffs, but this exception is expected to be very rare.

What Happens Now?
This decision means that federal judges can no longer routinely block federal policies nationwide. If you want to challenge a federal law or policy on behalf of a large group of people, you’ll probably need to file a class action lawsuit, a more complicated and time-consuming process than simply asking for a nationwide injunction. The ruling is seen as a win for the executive branch, which has long argued that nationwide injunctions give too much power to unelected judges. On the other hand, advocacy groups worry that it will be much harder to stop controversial federal policies quickly, potentially leaving some people without protection while cases wind their way through the courts.

The Bigger Picture

This ruling isn’t just about birthright citizenship, it’s about who gets to decide the reach of federal power. 

By Limiting Nationwide Injunctions, The Supreme Court
Has Shifted The Balance Away From The Courts
And Toward The Executive Branch.

While the door isn’t completely closed to broad injunctions, they’ll now be the exception, not the rule. Expect future legal battles to focus more on class actions and specific, case-by-case relief.

Bottom Line
The Supreme Court has made it much harder for federal judges to issue nationwide injunctions. This change will have a big impact on how quickly new federal policies can be challenged and stopped, and it’s likely to shape the way future presidents, judges, and advocates approach major legal fights.

Impact on IRS Layoffs
On March 25, 2005 we posted The IRS ‘Reinstated’ 7,000 Workers, But They Are Not Returning To Work where we discussed that the District Court determined that probationary employees are being rehired but then placed on administrative leave "en masse," the order said. 

“This is not allowed by the preliminary injunction, for it would not restore the services the preliminary injunction intends to restore.” Both judges ordered that the agencies offer to reinstate any probationary employees who had improperly been terminated. 

Neither order was a final decision in the case and the federal government will pay about 7,000 IRS probationary employees, who were laid off less than a month ago, not to work while lawsuits over layoffs wind their way through the court system, the agency said in an email.  

Now it appears that under this Supreme Court ruling, the District Court injunction only applies to those individuals who are parties to the case and the remaining 7000 workers can be fired.

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



Read more at: Tax Times blog

Why You Should File Your Tax Return Even If You Can’t Pay

Filing your tax return on time is essential, even if you can't pay the full amount you owe. Here’s why this matters and what you should do if you find yourself in this situation.

1. Avoid the Worst Penalties

The IRS imposes a much larger penalty for failing to file than for failing to pay. If you don’t file your return, the penalty can be 5% of the unpaid tax per month, up to 25%. If you file but can’t pay, the penalty is only 0.5% per month. Filing on time, even without payment, minimizes the amount of penalties you’ll face.

2. Keep Your Options Open

Filing your return allows you to access IRS payment plans and relief programs. You may qualify for an installment agreement, a short-term extension, or even a temporary delay in collections if you’re experiencing financial hardship. None of these options are available if you haven’t filed your return.

3. Limit Interest and Additional Charges

Interest and penalties start accruing the day after the tax deadline. Filing your return and paying as much as you can, even a partial payment, reduces the overall amount you’ll owe in the long run.

4. Protect Your Refund and Credits

If you’re owed a refund, you won’t receive it unless you file. Even if you owe, filing allows you to claim tax credits and deductions that could lower your balance due.

5. Avoid Escalating Enforcement

Failing to file can lead to aggressive IRS actions, such as tax liens, levies, or wage garnishments. Filing your return, even without payment, shows good faith and can help you avoid the harshest collection measures.

What to Do If You Can’t Pay

·         File your return by the deadline or request an extension.

·         Pay as much as you can, even if it’s not the full balance.

·         Consult with a tax professional to discuss payment options or relief programs.

·         Don’t ignore the problem; taking action is always better than doing nothing.

Filing on time, even if you can’t pay, is the smartest step you can take to protect yourself financially and legally. 

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






Read more at: Tax Times blog

IRS Agrees to Remove Willfulness Checkbox from Voluntary Disclosure Program: What It Means for Taxpayers


According to the Taxpayer Advocate, the IRS’s Criminal Voluntary Disclosure Practice (VDP) has long served as a crucial avenue for taxpayers with potential criminal tax exposure to self-correct, pay back taxes, penalties, and interest, and avoid criminal prosecution. When the program is fair and accessible, it benefits both taxpayers and the government by closing the tax gap and encouraging future compliance. However, changes made in 2018 made the VDP more burdensome and less attractive, leading to lower participation rates.

The Willfulness Checkbox: A Barrier to Participation

One of the most controversial changes was the addition of a “willfulness checkbox” on Form 14457, the VDP application. Taxpayers were required to check this box and explicitly admit, under penalty of perjury, that their noncompliance was willful. This admission carried significant legal risk, as it could be used against them if the IRS denied their participation or revoked their acceptance into the program. Unsurprisingly, this requirement had a chilling effect, discouraging many taxpayers and practitioners from using the VDP.

After advocacy from the Taxpayer Advocate Service (TAS), the IRS has agreed to remove the willfulness checkbox in the next revision of Form 14457. This move is a significant win for taxpayers, reducing the legal risk of self-incrimination and encouraging greater participation in the VDP. The recommendation is also that the IRS not require taxpayers to check the box on the current form while updates are underway.

Promising Steps: Program Review and Data Collection

Beyond the checkbox, the IRS has agreed to several other TAS recommendations aimed at making the VDP more accessible and effective. These include:

·         Convening a working group to comprehensively review the VDP, with input from stakeholders.

·         Narrowing the definition of illegal source income, which should broaden eligibility and encourage more taxpayers to come forward.

·         Collecting robust program data, including amounts collected through the VDP, to better measure its effectiveness.

A comprehensive review that includes stakeholder input is essential to ensure the VDP is viable and meets its goal of increasing compliance. Collecting data will also help the IRS evaluate the program’s success and make informed improvements.

Ongoing Challenges: Penalty Structure, Appeal Rights, and Payment Flexibility

Despite these positive steps, the IRS has declined to address some of the most significant barriers to VDP participation:

·         Penalty Structure: Currently, taxpayers must accept a six-year disclosure period and the 75 percent civil fraud penalty, as well as the willful FBAR penalty (if applicable) on the highest tax liability period. This one-size-fits-all approach can be excessively punitive and discourages participation, especially for those whose circumstances may not warrant such severe penalties.

·         Appeal Rights: Taxpayers in the VDP have no right to dispute the IRS’s determination of taxes, penalties, and interest. They must accept the IRS’s assessment or withdraw from the program.

·         Payment Flexibility: The VDP requires full payment at the close of examination or a full-pay installment agreement. Taxpayers unable to pay in full are removed from the program, leaving no room for alternative payment arrangements.

These rigid policies mean that taxpayers face a “take it or leave it” scenario, which can deter even those who want to come into compliance. Participation in the VDP remains low, with only 161 criminal VDP cases completed since 2019—a clear sign that the program’s structure and penalties are not working as intended.

Looking Ahead

The IRS’s agreement to remove the willfulness checkbox and collect program data signals positive change for taxpayers. However, real progress will require a willingness to reconsider the penalty structure, provide appeal rights, and allow flexible payment options. A truly comprehensive review of the VDP is needed to make it fairer and more effective, encouraging more taxpayers to come forward and resolve their tax issues.

Taxpayers and practitioners should watch for updates to Form 14457 and further changes to the VDP as the IRS continues its review. With continued advocacy and stakeholder input, there is hope for a more balanced and accessible voluntary disclosure program in the future.

 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

Bill Romanowski’s $15.5 Million Tax Nightmare: What Happened and What’s Next

$15.5 Million Tax Nightmare

Bill Romanowski, the hard-hitting linebacker who won four Super Bowls and became a household name in the NFL, is now at the center of a massive financial and legal crisis. Alongside his wife Julie, Romanowski faces a recommended federal court judgment to pay $15.5 million in unpaid taxes, penalties, and interest,
a saga that’s as dramatic as any football game he ever played.

How Did It Come to This?

The trouble began years ago, with the IRS and Department of Justice accusing the Romanowskis of failing to pay federal income taxes from 1998 to 2004 and again in 2007. The government’s lawsuit claims the couple owes more than $15.5 million, and that they went to great lengths to avoid paying. According to court filings, the Romanowskis used their nutrition supplement company, Nutrition53, to pay for personal expenses—everything from rent and groceries to their children’s living costs and even spa visits.

The government alleges that this was a deliberate strategy to shield their income and assets from tax collection. Prosecutors want the court to declare Nutrition53 the couple’s “alter ego,” meaning its assets could be seized to satisfy their tax debts.

Courtroom Drama and Missed Opportunities

Despite being served with the lawsuit and given multiple extensions, the Romanowskis failed to respond or appear in court. Their attorney admitted they were aware of the case and intended to defend themselves but said they were “overwhelmed” by the process. The judge was unsympathetic, noting that simply stating an intention to defend at some vague future date isn’t enough to avoid a default judgment.

The Department of Justice moved for a default judgment, and U.S. Magistrate Judge Peter H. Kang agreed, recommending that the Romanowskis be ordered to pay the full amount. The recommendation isn’t final yet—the couple can still file objections before the district court judge makes a final ruling. But if they don’t, or if their objections fail, the judgment will stand.

Bankruptcy and a Temporary Reprieve

As the legal noose tightened, the Romanowskis filed for bankruptcy—Nutrition53 filed for Chapter 11 last fall, and Bill and Julie filed for personal bankruptcy just one day before a key court hearing this spring. Under U.S. law, bankruptcy temporarily halts collection efforts, but it doesn’t erase tax debts. In fact, the bankruptcy court later converted their case to Chapter 7, which allows for the liquidation of assets to pay creditors, including the IRS.

What’s at Stake?

If the court’s recommendation is adopted, the Romanowskis will owe $15.5 million to the IRS, and the government could seize their assets—including those held by Nutrition53. Their financial future is in serious jeopardy, and the case serves as a stark warning about the consequences of ignoring tax obligations, no matter how successful or famous you might be.

A Legacy Beyond the Field

Romanowski’s football career was legendary: 16 seasons, four Super Bowl rings, and a reputation as one of the game’s toughest competitors. But his athletic achievements haven’t shielded him from the harsh realities of tax law and financial mismanagement. As the legal proceedings continue, the Romanowskis’ story is a reminder that even the biggest stars aren’t immune from the IRS.

Stay tuned, this legal battle is far from over, and its outcome could reshape the legacy of one of football’s most controversial figures.


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.law360.com/tax-authority/articles/2304053/judge-urges-15-5m-tax-judgment-against-ex-nfl-champ   

2.      https://www.coachesdatabase.com/bill-romanowski-irs-tax-debt-2024/       

3.      https://accountants.intuit.com/community/tax-talk/discussion/romanowski-case/00/301461 

4.      https://www.on3.com/pro/news/bill-romanowski-allegedly-owes-more-than-15-million-in-unpaid-taxes/  

5.       https://people.com/super-bowl-champion-bill-romanowski-files-bankruptcy-over-15-million-unpaid-taxes-8642441   

6.      https://bleacherreport.com/articles/10119319-former-nfl-lb-bill-romanowski-files-for-bankruptcy-allegedly-owes-15m-in-back-taxes   

7.       https://www.usatoday.com/story/sports/nfl/2024/04/30/bill-romanowski-bankruptcy-lawsuit-unpaid-taxes/73513612007/ 

8.      https://www.law360.com/bankruptcy-authority/articles/2295131/ex-nfl-star-romanowski-s-bankruptcy-converted-to-ch-7  

9.      https://en.wikipedia.org/wiki/Bill_Romanowski  

10.   https://www.sportingnews.com/us/nfl/news/super-bowl-wins-player-list-most-rings/3b80882eaa591e67ce7dca1b  

Read more at: Tax Times blog

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