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Tax Fraud Blotter: Shame shame

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Careless; the PTIN shuffle; time for Time; and other highlights of recent tax cases.

Washington, D.C.: Recent IRS Office of Professional Responsibility disciplinary sanctions include censure, suspension or disbarment from practice before the IRS. Individuals disciplined include (all dates 2024):

  • Milton, Georgia: CPA Peter J. Tarantino, indefinite from July 22.
  • Hampton, Iowa: Attorney Daniel F. Wiechmann Jr., indefinite from July 18.
  • St. Louis: CPA Richard L. Van De Riet, indefinite from Aug. 20.
  • New City, New York: CPA George J., Silverman, indefinite from Aug. 14.
  • Shelby, North Carolina: Appraiser Walter “Terry” D. Roberts II, indefinite from Aug. 2.
  • Philadelphia: CPA Howard C. Lapensohn, indefinite from July 22.
  • Signal Mountain, Tennessee: Attorney David J. Fulton, indefinite from Aug. 8.
  • Round Rock, Texas: CPA Chuks L. Iheke, indefinite from Aug. 21.

Meanwhile CPA John J. Savignano, of White Plains, New York, was reinstated to practice before the IRS effective July 17.

Albuquerque, New Mexico: Stacy Underwood, third and final defendant in a tax scheme that operated for more than a decade, has been sentenced to time served to be followed by three years of supervised release, and ordered to pay more than $5.5 million restitution.

David Wellington of Albuquerque was previously sentenced to 40 months in prison and ordered to pay more than $5.5 million restitution for his role; he was also permanently prohibited from running any business advising clients or dealing with the IRS. Jerry Shrock, of Meadowview, Virginia, was sentenced to five years of probation and ordered to pay $1.5 million in taxes, interest and penalties.

Between 2005 and 2015, Wellington and Underwood operated National Business Services, which specialized in creating LLCs for clients seeking to evade federal taxes. The pair organized at least 192 LLCs in New Mexico and opened at least 114 bank accounts for these clients.

Underwood was sole signer for 99 of these accounts, allowing clients to conduct financial transactions anonymously. From January 2011 to July 31, 2018, more than $40 million was deposited into clients’ accounts nominally controlled by Underwood.

Shrock had three LLCs formed by National Business Services while undergoing an IRS audit. Between 2011 and 2015, he deposited nearly $4.9 million into a bank account opened for one of his LLCs, concealing more than $4.3 million in income without filing returns.

Syracuse, New York: Robert Rahrle, formerly of Florida and now residing in New York, has pleaded guilty to tax evasion and wire fraud.

Rahrle admitted that from 2017 through 2024 he ran a fraudulent online gift basket website called iCare Gifting Solutions LLC, which purported to cater to families of incarcerated individuals, promising to send care packages into prisons. The company charged hundreds of customers some $50 a basket but never sent the gift packages.

He also evaded federal taxes; he self-prepared and filed returns for 2017 and 2018 that falsely reported business losses and failed to report hundreds of thousands of dollars of gross receipts.

Sentencing is June 11. Rahrle faces up to five years in prison on the tax evasion charge and up to 20 years on the wire fraud charge, along with a post-imprisonment term of supervised release of up to three years. He could also be fined up to $250,000 or a fine based on his gain or the victims’ losses; he owes restitution to the IRS of some $175,000 and restitution to the victims of his fraud; and he must forfeit $2 million to the United States. 

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Germantown, Wisconsin: IT consultant Vikram Naik has submitted what authorities called a “shamefaced plea” to one count of filing a false individual income tax return.

He was indicted in October with three counts of filing false 1040s for 2017, 2018 and 2019. Naik had federal income tax withholding amounts that were substantially less than he reported on each of the federal returns he filed and had taxable income and total tax owed greater than he reported.

Naik owned and operated Naik Consulting Inc. since 2015, providing services to some clients who treated him as an employee, paid him wages and provided W-2s. Other clients treated Naik as a contractor. Naik was his company’s only employee, and he issued himself a W-2.

From 2016 through 2019, Naik inflated withholdings on his 1040s. He falsely reported on W-2s from his company that it had withheld federal income tax from his wages of $60,000 in 2017, $61,500 in 2018 and $146,000 in 2019. Naik Consulting never actually withheld and paid over to the IRS any federal income taxes from Naik’s wages. He did the same with some of his consulting clients in tax years 2018 and 2019, as well as his wife’s employer in 2018, inflating the federal income tax withheld. His 1040s claimed that he was entitled to sizable refunds for each of those years.

He caused a tax loss of some $277,257.

Sentencing is March 21. Naik faces up to three years in prison and a $250,000 fine, as well as a term of supervised release after any imprisonment.

St. Louis: Tax preparer Shasherese M. Reed, 53, has admitted preparing fraudulent tax returns.

Reed admitted using a tax prep business, Majac Money, which was opened by her daughter because the IRS revoked the PTIN assigned to Reed and her business, Sha-Sha Taxes, in 2015. Reed falsely identified her daughter as the paid preparer on the returns that Reed prepared at Majac Money.

On these returns, Reed commonly included a false Schedule C that reported tens of thousands of dollars in business expenses when the taxpayer either had substantially smaller expenses or did not own a business. Reed also claimed false and fraudulent deductions for such items as state and local taxes, medical and dental expenses, and mortgage interest.

She admitted preparing a fraudulent return for an undercover IRS agent; without asking if the agent had a business, Reed prepared a return that included a false Schedule C showing $26,242 in expenses.

Reed charged clients hundreds of dollars in fees for preparing returns, making about $378,026 in fees for the 2017 to 2021 tax years. She prepared at least 41 false tax returns for 13 different taxpayers, costing the IRS at least $312,192.

Sentencing is May 6.

Montgomery, Alabama: Tax preparer Natoshia Lashawn Crawford, 47, has been sentenced to 30 months in prison for making false returns and assisting in the filing of false returns.

From 2018 through 2022, Crawford owned and operated On Time Professional Tax Service, where she prepared and filed federal income tax returns for clients. Crawford admitted that she included false information on returns filed on behalf of herself and others to, in some cases, inflate refunds.

In one example, Crawford reported a total income of $23,116 in her 2020 return and when she pleaded guilty in May admitted that she knowingly excluded other income from her business. The false reporting of Crawford’s income for 2020 resulted in a lower amount of tax due and an underpayment to the IRS of $32,867.

Crawford further admitted to filing a 2019 return for a client claiming a loss of $90,171 for a janitorial services business that did not exist and admitted that multiple false returns she filed for herself and others during the 2017 to 2021 tax years caused a total loss of $1,721,047.45 to the IRS.

Crawford was also ordered to pay restitution to the IRS.

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Interim guidance from the IRS simplifies corporate AMT

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Jordan Vonderhaar/Photographer: Jordan Vonderhaar/

The Internal Revenue Service has released Notice 2025-27, which provides interim guidance on an optional simplified method for determining an applicable corporation for the corporate alternative minimum tax.

The Inflation Reduction Act of 2022 amended Sec. 55 to impose the CAMT based on the “adjusted financial statement income” of an “applicable corporation” for taxable years beginning in 2023. 

Among other details, proposed regs provide that “applicable corporation” means any corporation (other than an S corp, a regulated investment company or a REIT) that meets either of two average annual AFSI tests depending on financial statement net operating losses for three taxable years and whether the corporation is a member of a foreign-parented multinational group.

Prior to the publication of any final regulations relating to the CAMT, the Treasury and the IRS will issue a notice of proposed rulemaking. Notice 2025-27 will be in IRB: 2025-26, dated June 23.

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In the blogs: Whiplash | Accounting Today

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Conquering tariffs; bracing for notices; FBAR penalty timing; and other highlights from our favorite tax bloggers.

Whiplash

Number-crunching

  • Canopy (https://www.getcanopy.com/blog): “7-Figure Firm, 4-Hour Workweek: 5 Questions to Ask Yourself.”
  • The National Association of Tax Professionals (https://blog.natptax.com/): This week’s “You Make the Call” looks at Sarah, a U.S. citizen who moved to London for work in 2024. On May 15, 2025, it hit her that she forgot to file her 2024 U.S. return. Was she required to file her 2024 taxes by April 15?
  • Taxable Talk (http://www.taxabletalk.com/): Anteing up with Uncle Sam: The World Series of Poker is back, and one major change this year involves players from Russia and Hungary. After suspension of tax treaties with those nations, players will have 30% of winnings withheld. 
  • Parametric (https://www.parametricportfolio.com/blog): Direct indexing seems to come with a common misunderstanding: On the performance statement, conflating the value of harvested losses with returns. 

Problems brewing

  • Taxing Subjects (https://www.drakesoftware.com/blog): No chill is chillier than the client’s at the mailbox when an IRS notice appears out of the blue. How you can educate — and warn — them about the various notices everybody’s that favorite agency might send.
  • Dean Dorton (https://deandorton.com/insights/): Perhaps because they can be founded on trust, your nonprofit clients are especially vulnerable to fraud.
  • Global Taxes (https://www.globaltaxes.com/blog.php): When it’s your time, it’s your time: The clock starts on FBAR penalties when the tax forms are due and not when penalties are assessed — and even the death of the taxpayer doesn’t extend the deadline.
  • TaxConnex (https://www.taxconnex.com/blog-): Your e-commerce clients can muck up sales tax obligations in many ways. How some of the seeds of trouble might hide in their own billing system.
  • Sovos (https://sovos.com/blog/): What’s up with the five states that don’t have a sales tax?
  • Taxjar (https://www.taxjar.com/resources/blog): Humans are still needed to handle sales tax complexity, with real-world examples.
  • Wiss (https://wiss.com/insights/read/): A business — and business-advising — success story from a California chicken eatery.

Almost half done

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What the House gave the Senate: Inside the Big Beautiful tax bill

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The reconciliation bill passed by the House on May 22 is currently being considered by the Senate, and will likely undergo changes before approval by the upper chamber. To what extent the changes will create stumbling blocks before a final bill is produced and voted on is uncertain, with the increased SALT deduction, Medicaid reforms, and repeal of certain Inflation Reduction Act credits on the line. 

While much can change between now and the final version of the bill, the following is a quick overview of some of the provisions:

  • Bonus depreciation. First-year bonus depreciation, currently being phased down 20% per year since 2023, is 40% for 2025, and will drop to 0% in 2027. Under the One Big Beautiful Bill Act (or OBBBA) it will be reset at 100% for eligible property acquired and placed in service after Jan. 19, 2025, and before Jan. 1, 2030.
  • Section 199A Qualified Business Income deduction. The QBI deduction, created by the Tax Cuts and Jobs Act, is available through 2025 to owners of pass-through entities, sole proprietors and the self-employed. The OBBBA would make the deduction permanent, and the deduction would increase to 23% for tax years beginning after 2025.
  • Domestic research and experimental expenditures. The OBBBA would reinstate the deduction available to businesses that conduct research and experimentation. Expenses incurred after 2024 and before 2030 would be eligible. 
  • Section 179 expensing. The bill increases the limit to $2.5 million and increases the phaseout threshold to $4 million for property placed in service after 2024. The limit and threshold would be adjusted annually for inflation.
  • Excess business loss limitation. The bill makes permanent the excess business loss limitation for pass-through entities.
  • Pease limitation. The bill would make permanent the repeal of the Pease limitation on itemized deduction, but would introduce a new limitation for taxpayers in the 37% bracket for years after 2025. It would also temporarily increase the standard deduction for tax years 2025 through 2028.
  • The Child Tax Credit. The bill makes the CTC permanent and raises it to $2,5000 per child for tax years 2025 through 2028, after which it would return to its present $2,000 with an annual inflation adjustment. 
  • Federal gift and estate tax exemption. The bill increases the federal gift and estate tax exemption to $15 million, and adjusts it annually for inflation. It is currently set at $13.99 million.

One sector the bill is very positive for is real estate, according to Tyler Davis, president of Saunders Real Estate: “It makes a lot of the TCJA provisions permanent. The estate tax exemption is made permanent and raised to $15 million, and the bonus is back to 100% for the next four years. This allows purchasers to depreciate their investments a lot faster, so it makes deals more attractive for investors and developers. A special provision for industrial manufacturing property under the bill, it is eligible for 100% expensing.”

Rural land for sale

Photographer: Nikita Sobolkov/nikkytok – stock.adobe.com

This would allow 100% of a project’s cost to be deducted in the first year, making it “hugely attractive,” he said. “The administration wants to bring investment back to the U.S. This will incentivize that process.”

Under the bill, the Section 163(j) business interest deduction would expand and allow more interest to be deducted on qualifying real estate, he said. “And they’re redoing some of the Opportunity Zone rules and boundaries, and are lowering reinvestment thresholds for investments. This should drive more investment into rural communities. And, lastly, there are no Section 1031 changes in the bill. That’s a really positive thing from a transactions and reinvestment perspective.”

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