TAX FRAUD & MONEY LAUNDERING
University of Houston Law Center

Larry Campagna
Chamberlain, Hrdlicka, etc.
Tel: 713-654-9609
larry.campagna@chamberlainlaw.com
Jack Townsend
Townsend & Jones, L.L.P.
Tel: 713-521-9977
jack@tjtaxlaw.com

Summary of Course

This course deals with tax crimes and some of their companion crimes.   The class will cover the following subjects:

Course Materials

The Book for this class is Townsend, Campagna, Johnson & Schumacher, Tax Crimes (Lexis-Nexis 2008).   There is a 2013 supplement available for download here.  In addition, I will post Update, Errata and Other Materials.  These should be reviewed periodically for important recent updates and corrections to the text (errata).

Student Information

Information - Introductory Information for the Class

Student Questionnaire - Each student should email to jack@tjtaxlaw.com the following information (please note that the email will be used for normal class communications; the other contact information will be used rarely if at all to get information to you such as cancellation of the class on short notice)..  

Name:
Cell phone number:
preferred email address for class communications.
Current employer:
Work phone number:
Degree program (JD / LLM):
If LLM, where did you get your JD degree:
Personal Goals for Class:
Prior work experience (after college, such as law, CPA, accounting:

Spring 2013 Course Schedule

(Class time is 5:30 - 7:10 pm)

Assignments for Classes   (Please note that the assignments are approximate and may vary as we move through the materials).  Please note that updates will be posted on the web site and sent to the members of the class by email.

Class 1
1/14
Introduction to Class
Ch. 1 Overview of the Criminal Tax System, pp. 1-18
Ch. 1 Update Items
Class 2
1/28
Ch. 2A Crimes Under the Internal Revenue Code - Tax Evasion, pp. 19 - 54
Ch. 2A Update Items
Class 3
2/4
Ch. 2B Crimes under the Internal Revenue Code - Other Offenses,  pp. 57 - 96
Ingredient Technology p. 61 -
U.S. v. Kelly p. 70 -  Anderson, Baumann, Beal, Cochran
U.S. v. Kassouf p. 72 - Damys, Dizon, Greer, Hall, Jezari
U.S. v. Evangelista p. 80 - Lawal, Shaffer, Simons, Stfort, Willey
Reminder: Compete and Return the Questionnaire - click here.
Ch. 2B Update Items
Class 4
2/11
 
Ch. 3 Crimes Outside the Internal Revenue Code, pp. 97 - 126
Ch. 3 Update Items
Case Assignments:
  United States v. Krasovich (p. 100) - Anderson, Baumann, Beal, Cochran, Damys, Dizon
  United State v. Caldwell (p. 107) -  Greer, Hall, Jezari, Lawal, Shaffer, Simons, Stfort, Willey
Class 5
2/19
 
Ch. 4 Methods of Proof, pp. 127 - 157
Ch. 4 Update Items
Case Assignments:
   United States v. Tarwater (p. 129) - Anderson, Baumann
   Holland v. United States (p. 134) - Cochran, Damys
   Taglianetti v. United States (p. 138) - Greer, Hall
   United States v. Esser (p. 141) - Lawal, Shaffer
   United States v. Black (p. 144) - Stfort, Willey
   United States v. Pree (p. 147), United States v. Sabino (p. 148); & United States v. Bishop (p. 149)
 -  Beal, , Dizon
   United States v. Tarwater (p. 150) - Jezari, , Simons
   United States v. Silkman (p. 155) - Unassigned (All read)
Class 6
2/25
 
Ch. 5 Prosecution Policies and Affirmative Defenses, pp. 159 - 182
Ch. 5 Update Items
Ch. 6 Investigation and Development of Criminal Tax Cases, pp. 183 - 197
Ch. 6 Update Items
Case Assignment:
   Sansone (p. 166) - All Class Members
Class 7
3/4
Ch. 6 Investigation and Development of Criminal Tax Cases (cont.), pp. 197 - 220
Ch. 6 Update Items
Ch. 7 Government Information Gathering, 221 - 232
Ch. 7 Update Items
Case Assignments:
   Tenzer (p. 207) -  Anderson, Baumann, Beal, Cochran, Damys, Dizon
   Lefkowitz (p. 229) - Greer, Hall, Jezari, Lawal, Shaffer, Simons, Stfort, Willey
Class 8
3/18
 
Ch. 7 Government Information Gathering, 232 - 252
Ch. 7 Update Items
Ch. 8 Pre-Trial Issues in Criminal Tax Cases, 253 - 274
Ch. 8 Update Items
Class 9
3/25
 
Chs. 7 & 8 Conclude with discussion of Problems from the Chapters.
Ch. 9 Trial and Post-Trial, pp. 277 - 299
Ch. 9 Update Items
Case Assignments:
   Johnson (p. 286) - Damys, Dizon, Greer, Hall, Jezari, Lawal, Shaffer
   Evangelista (p. 288) - Anderson, Baumann, Beal, Cochran, Simons, Stfort, Willey
Class 10
4/1
 
Ch. 10 Sentencing in Tax Cases, 301 - 329
Case Assignments:
   Mistretta (p. 308) - Baumann, Beal, Lawal
   Booker (p. 311) - Anderson, Cocharn, Shaffer, Greer
   Chavin (p. 323) - Damys, Willey, Simons
   Harvey (p. 327) - Dizon, Stfort, Jezari
Ch. 10 Update Items
Class 11
4/8
Ch. 11 Ethical Issues in Criminal Tax Practice, pp. 331 - 358
Case Assignments
   United States v. Locascio (p. 345) - Anderson, Baumann, Beal, Cochran, Damys
   Paratechnologies Trust v. Commissioner (p. 349) - Dizon, Greer, Hall, Jezari, Lawal
   Lefcourt v. United States (p. 353) - Shaffer, Simons, Stfort, Willey
Ch. 11 Update Items
Class 12
4/15
Ch. 12 Major Collateral Issues, p. 361 - 373
Ch. 12 Update Items
Ch. 13 Civil Tax Considerations, pp. 377 - 392
Ch. 13 Update Items
Class 13
Friday
4/26
 
This class is canceled and the class function is substituted.
The function is Friday, 4/26.   The function will be at Larry Campagna's house.  Class members on the email list should have received an email with the address and the map to the house.  If you are a member of the class and did not receive the email or want it to be resent, please email my assistant, Merry Davis at merry@tjtaxlaw.com and she will return email you the information.
Spouses, significant others, etc. are invited (only one per class member so as to not create a ruckus between a spouse and a significant other)
Class 14
4/29
Ch. 14 Putting It All Together, pp. 395 - 411
Ch. 14 Update Items
Examination Review
Exam
TBA

Past Examinations.  For viewing or download.

 Miscellaneous Notes to Students

Excerpts from Examinations: Students Say the Darndest Things

These are some excerpts from students' answers to the 1997 examination. The students are anonymous to me in the grading process, so I don't know who gave these answers.

I think the practical solution is this: Jones should burn his original diary. The IRS doesn’t know of its existence and Jones sure as hell isn’t gonna tell them about it. So he should be able to avoid obstruction charges (provided his psychiatrist is the only other party who knows of the diary’s existence.) Then when the IRS asks the Dr. for his copy of correspondence from Jones, the psychiatrist can rightly refuse, citing the client-patient privilege. I really think this should hold up. The privilege is legit, and the papers were obtained by the doctor in the course of treatment for treatment purposes. Although it may border on the unethical, I think the client’s neck, in this instance, demands disposal of the original. (Of course, the atty-client privilege may be waived here under the crime-fraud rule if the advice is "obstruct-justice." But if the initial meeting and discussion were generally enough phrased, I think the professional responsibility teachers would agree with me."

JAT Comments: Some things do not require comment, but this answer does suggest that we spend a bit more time on ethics and illegal conduct on the part of the practitioner.

University of Houston Law Center HomePage


Return to Townsend & Jones, L.L.P. Homepage

Hit Counter