Attorney-at-Law

ONE FOR SIX

In Uncategorized on 07/26/2021 at 16:53

Not a great batting average, and it only saves George S. Harrington, 2021 T. C. Memo. 95, filed 7/26/21, $4500 in deficiency and chop, because IRS couldn’t prove fraud for that year and admitted it. But George really shouldn’t have gotten involved with UBS and their tax-dodging ways.

George was a lumber finder for a Canadian exporter. He met their counsel, Mr. G., “who seemed ‘on the ball.’ Petitioner described Mr. G and his associates as ‘the most honorable people I have ever dealt with.’ Mr. G was later imprisoned for embezzlement.” 2021 T. C. Memo, 95, at p. 4. (Name omitted).

It may well be that Mr G and his associates were in fact the most honorable people George ever dealt with, because after that he hung out with a band of tax-dodging crooks. The UBS crew put George and Mrs George into offshore trusts, hidden bank accounts, and phony life insurance policies, running from the Cayman Islands to Switzerland to Liechtenstein. George claims he didn’t know what was going on and had no control over the million bucks or so he stashed.

Except.

The Swiss rolled on him after they signed the famous deferred prosecution agreement with Treasury, and handed over the accounts, e-mails, and phonecalls.

I’ll spare you the lengthy account. Judge Albert G (“Scholar Al”) Lauber finds enough badges of fraud to make George a Vulture Scout. Barring the one year, George is in for quite a Rule 155 beancount.

  1. A busy Monday but the amusement should not be overlooked. Judge Holmes had to vacate the decision he had entered just last Friday. This was in the Caylor case, involving a dozen petitions from 2013 and 2014, on which not much had happened since a trial in 2016 and briefing through 2018. The March 2021 opinion promised orders to follow. In the first attempt, the decision found the following amounts owed by one of the petitioners:

    Year Tax 6662 Penalty

    2010 59,492 1,902

    2011 11,898 380

    Today, it’s not so much tabula rasa as tabular erasure:

    2010 59,492 11,898

    2011 1,902 380

    TCM 2021-30; Docket No. 17204-13

    (Blogged extensively, in the past decade.)

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  2. It’s well-known I’m a Holmesian (both the Baker Street and the Second Street varieties), so thanks to Mr Kamman for pointing this out. I’ll cut Judge Holmes a wee bit of slack here. This long-running production would stupefy anybody.

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