Procedural Issues
Cousin Jedediah

Understanding Parallel Civil and Criminal Investigations

Jedediah was an entrepreneurial soul.  You may remember him from the Deductibility of Criminal Restitution article, but if not, he may or may not have been pinched for embezzling money from Ned’s Tire Rack.  It turns out that he had embezzled the money from Ned, a true southern gentleman, who could sell a whitewall to a Goodyear heir, in order to finance a pyramid scheme involving ethnocentric vitamins and supplements, like his personal hero Joseph

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Scott St. Amand April 29, 2021
Procedural Issues
Abuse of Discretion

Doyle v. Commissioner
T.C. Memo. 2020-139

On October 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Doyle v. Commissioner (T.C. Memo. 2020-139). The issue before the court in Doyle v. Commissionerwas whether the IRS’s Whistleblower Office abused its discretion in issuing a determination which denied the petitioners’ two whistleblower claims based on the ground that the IRS took no action based on the information that the petitioners provided, even though the Criminal Investigative Division was unclear

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Scott St. Amand October 8, 2020
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Understanding Parallel Civil and Criminal Investigations

Jedediah was an entrepreneurial soul.  You may remember him from the Deductibility of Criminal Restitution article, but if not, he may or may not have been pinched for embezzling money from Ned’s Tire Rack.  It turns out that he had embezzled the money from Ned, a true southern gentleman, who

Read More »
Scott St. Amand April 29, 2021

Doyle v. Commissioner
T.C. Memo. 2020-139

On October 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Doyle v. Commissioner (T.C. Memo. 2020-139). The issue before the court in Doyle v. Commissionerwas whether the IRS’s Whistleblower Office abused its discretion in issuing a determination which denied the petitioners’ two whistleblower claims based

Read More »
Scott St. Amand October 8, 2020