September 3, 2021 | Briefly Taxing

A Necessary Conversation: Explaining FBAR Filings to the Uninitiated

Explaining FBAR Filings to the Uninitiated This is not the normal Briefly Taxing post. Usually, I post articles written exclusively for the blog, but today I am excited to post an article I wrote for someone else. In late July, I received a comment on the blog from an editor at Bloomberg Law, saying that she had read one of my posts, and asking whether I would be willing to write for them. I pitched two ideas for an article, and they asked me to write both. So I did. Earlier today, Bloomberg Law published my first article in their Tax Management Memorandum. The article is entitled A Necessary Conversation: Explaining FBAR Filings to the Uninitiated, 62 Tax Mgmt. Memo. No. 19, 229 (Sept. 13, 2021). Although Bloomberg Tax is a subscription service (and very worth it!), the editors have allowed me to reproduce it on the…

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September 3, 2021

Memorandum Opinions / Penalties Under the Code / Tax Opinions

Catlett v. Commissioner
T.C. Memo. 2021-102

On August 16, 2021, the Tax Court issued a Memorandum Opinion in the case of Catlett v. Commissioner (T.C. Memo. 2021-102). The primary issue presented in Catlett v. Commissioner was whether the IRS satisfied its burdens of production and proof to dismiss the petition for lack of prosecution…because the petitioner died…in prison…on a 17 ½ year stint in the hoosegow for tax crimes and conspiracy to defraud the United States. Background to Catlett v. Commissioner Irvin Hannis Catlett, Jr. was not good at taxes…in life or in death. You see, Irvin ran a tax mill called Tax Resolutions, Inc. in Maryland. In the early 2000s, ol’ Irvin devised a tax shelter scheme. But Irvin wasn’t alone. Oh, no...he wasn't alone by a long shot... Irvin had a man on the inside—Mark Hunt, and IRS officer. Irvin incorporated sham entities that the Tax Court referred to collectively as Motors Holding. He urged…

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September 3, 2021