The Internal Revenue Service's struggles in the face of limited resources are well-documented. Over the past decade, the IRS's budget has increased only 9%...

On Monday, a federal judge took the unusual step of granting former President Donald J. Trump's request for a special master to review more than 11,000 documents and 1,800...

On September 13th, Morvillo Abramowitz Partner Brian A. Jacobs was again on NewsNation's "Banfield," together with Tara Wall, discussing the latest developments in the DOJ's...

When in-house counsel gives legal advice mixed with business advice, their two roles open themselves up to potentially discoverable communications. Although, at least in the United States,...

In Salinas, two individuals were shot and killed, and the police recovered six shotgun shell casings at the scene.

After a meteoric rise in the first half of 2021, the super-SPAC Pershing Square Tontine Holdings ("PSTH") has come crashing down to earth.

Although parties often argue in favor of literal readings of statutes, and courts often accept such readings, courts may decline to read a statute literally where a literal reading would conflict with other accepted legal principles or policies.

On Aug. 2, 2022, the New York State Department of Financial Services (DFS) announced a consent order with Robinhood Crypto (RHC), the virtual currency trading platform of mobile trading...

The recent acquittal in the Eastern District of New York of Thomas Barrack, a longtime friend and ally of former President Donald Trump, who was accused of acting as an unlawful agent...

The current U.S. Supreme Court term promises to be an especially important one for tax practitioners. In addition to the recent arguments in Bittner v. United States...

When parties with a common interest share attorney work product with each other in anticipation of litigation, the parties often expect that the work product will be immune from disclosure in the subsequent litigation.

When a defendant enters into a deferred prosecution agreement (DPA) or other agreement with the government, the government often insists on the inclusion of factual admissions.

A ccording to its mission statement, the Internal Revenue Service seeks to "[p]rovide America's taxpayers top quality service by helping them understand and meet their tax responsibilities...

The legal commentariat seems to have settled on the view that newly confirmed Supreme Court Justice Neil Gorsuch will fill the seat left by the late Justice Antonin Scalia...

Each year the Internal Revenue Service assesses billions of dollars in civil penalties against taxpayers. In 1998, Congress adopted §6751(b) of the Internal Revenue Code, which imposes a procedural...

The prosecution of corporations has become a mainstay of federal white-collar criminal enforcement. Why is that? Corporations cannot be sent to prison and they act only through individuals.

When parties agree to arbitrate their disputes, they consent to have an arbitrator, rather than a court, resolve disputes about whether particular documents are discoverable, including whether the documents are privileged.

For many years the Department of Justice (DOJ) has sought to encourage voluntary disclosure of wrongdoing by companies.

No federal statute defines "insider trading." Instead, the common law crime of securities "insider trading" has evolved from a convoluted collection of factspecific court decisions...

For more than a decade, the government has pursued taxpayers who failed to report offshore accounts on Reports of Foreign Bank and Financial Accounts (FBARs).