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Reconstructing deblis

HOW THE IRS RECONSTRUCTS INCOME IN TAX FRAUD CASES

Cost Free
Presentation Length 1.5 hours

Recorded DateMarch 15, 2019
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

In one of the climactic scenes from 1954’s On The Waterfront, Crime Commission prosecutors had to make their corruption case against union boss Johnny Friendly (a/k/a Michael Skelly) by convincing a reticent yet pure-hearted Terry Malloy to come forward and tell what he knew about corruption in the International Longshoremen’s Association, beginning with the murder of Joey Doyle, because an underling insisted that “we were robbed last night and can’t find no books.”
 
If that same case came up in 21st Century tax court, Eva Marie Saint and Karl Malden could’ve stayed at home rather than serving as Marlon Brando’s cheering section, because government prosecutors could reconstruct the ILA’s income, based on the records retention requirements in Section 6500 et seq.
 
In other words, the conventional wisdom that only divine beings can create something out of nothing does not apply in income tax evasion cases. Is it enough for the government to pull a metaphorical rabbit out of a metaphorical hat, or are there some additional requirements?

Learning Objectives:


  • Elements of Tax Evasion

  • Define Substantial Tax Deficiency

  • Methods of Proof

PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Michael is a partner in the boutique law firm of DeBlis Law where he specializes in tax compliance and entertainment law. Michael graduated from Western Michigan University School of Law in 2007 and later went on to earn his Masters of Law in taxation (LL.M.) from Thomas Jefferson School of Law in 2012.

As a former public defender, Michael has spent nearly eight years cutting his teeth on some of the most serious felony cases to pass through the state courts of New Jersey.

Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of federal taxation make him uniquely qualified to handle any white-collar case, no matter how sophisticated it might be.

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