Category: Tax Cases


Robert F. Smith

Background and Non-Prosecution Agreement


Mr. Smith in 2020, at the age of 57, entered into a Non-Prosecution Agreement, NPA, with the IRS.   Let’s look at what I believe happened to Mr. Smith to cause his personal and professional life to intersect with potential Criminal Prosecution with the United States Government.  Let’s also see what could have been done differently to head off such a horrible outcome to his reputation, his freedom, and a lifelong stain on his legacy.

Finally, let’s see if this is now the end of Mr. Smith’s criminal and civil problems with the successful negotiation of this NPA.



10.82 Expedited suspension (a) When applicable. Whenever the Commissioner, or delegate, determines that a practitioner is described in paragraph (b) of this section, the expedited procedures described in this section may be used to suspend the practitioner from practice before the Internal Rev


On May 17, 2017, less than 2 months ago, powerful members of the U.S. Congress sent a letter to John Koskinen, the Commissioner of the Internal Revenue Service, requesting information about the IRS’s digital currency strategy as well as recent events surrounding the IRS’s summons to Coinbase, a digital asset exchange company.

The three Congressional members drafting this letter were:

1. Orin G. Hatch, Chairman of the Senate Committee on Finance; 2. Kevin Brady, Chairman of the House Committee on Ways and Means; and 3. Vern Buchanan, Chairman of the House Committee on Ways and Means Oversight Subcommittee


In March 2014, the IRS began working to clarify tax issues related t

On February 3, 2017, U.S. Magistrate Judge Thomas Rueter ruled that Google must provide emails stored overseas to the FBI for their domestic fraud investigation, despite an earlier decision finding no such obligation for Microsoft. The ruling was made in Philadelphia that transferring emails from a



On November 17, 2016 the formal litigation commenced between the San Francisco virtual currency corporation, Coinbase, by an administrative “John Doe” summons to Coinbase

The attorneys for the Government are very heavy in experience for complex litigation and criminal litigation; they are:

1. CAROLINE D. CIRAOLO, Principal Deputy Assistant Attorney General 2. JEREMY N. HENDON, Trial Attorney for the U.S. Department of Justice, (DOJ) 3. AMY MATCHISON, Trial Attorney United States Department of Justice, (DOJ) 4. BRIAN J. STRETCH, United States Attorney 5. THOMAS MOORE, Chief, Tax Division 6. COLIN C. SAMPSON, Assistant United States Attorney

The above Government attorneys filed in the U.S. District Cou

The Internal Revenue Service (IRS) is continuing to develop and solidify its encompassing strategy for an individual’s compliance when using virtual currencies. At this point, the IRS has now defined virtual currencies as both a property and a currency. As the IRS gains more depth and a clearing u
On August 19, 2014, Bernard Kramer pleaded guilty in the Southern District of New York to conspiracy to defraud the United States and filing a false income tax return relating to his concealment of at least $1.1 million in bank accounts in Switzerland and Israel. For 23 years, Kramer had an undeclar

Department of Justice Office of Public Affairs FOR IMMEDIATE RELEASE Monday, August 4, 2014 Mizrahi Bank Client Sentenced for Filing False Tax Return California Resident the Latest in Series of Defendants Prosecuted for Concealing Accounts at Israeli Banks

A Beverly Hills, California man was sentenced today in the U.S. District Court for the Central District of California to serve six months in prison and one year of home confinement for filing a false federal income tax return for tax year 2007, the Justice Department and Internal Revenue Service (IRS) announced.

According to court documents, Monajem Hakimijoo aka Manny Hakimi, a U.S. citizen, and his brother maintained an undeclared bank account at Mizrahi Bank in Israel in the name of Kalamar Enterprises, a Turks and Ca