EFTA01125419Set 9
2012-01-03101p22,011w
conducted an investigation regarding
a conspiracy among Wegelin & Co. ("Wegelin"), more than 100 U.S.
taxpayer-clients of Wegelin, and others known and unknown to
defraud the United States of certain ... other things, concealing from the Internal Revenue Service
("IRS") undeclared accounts owned by U.S. taxpayers at Wegelin
and other Swiss banks. As set forth below, it was part of this ... scheme to provide U.S. taxpayer-clients of Wegelin and other
Swiss banks who had undeclared accounts in Switzerland access to
their undeclared funds in the United States in a manner
https://www.justice.gov/epstein/files/DataSet%209/EFTA01125419.pdf
EFTA02711179Set 11
2014-01-179p6,750w
request for assistance. This advice may not be used or cited as
precedent.
LEGEND
Taxpayer =
Bank =
Years =
ISSUES
1. Does a change in accounting method under IRC § 446 occur when ... Taxpayer no longer treats
certain securities transactions as "options?"
2. If a change in accounting method does occur when these transactions that were treated as
options no longer are treated ... computed?
CONCLUSIONS
1. A change in accounting method under IRC § 446 occurs when Taxpayer no longer treats certain
securities transactions as options and thus, stops deferring the gains, losses, income
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02711179.pdf
EFTA01193903Set 9
2014-01-179p6,733w
request for assistance. This advice may not be used or cited as
precedent.
LEGEND
Taxpayer =
Bank =
Years =
ISSUES
1. Does a change in accounting method under IRC § 446 occur when ... Taxpayer no longer treats
certain securities transactions as "options?"
2. If a change in accounting method does occur when these transactions that were treated as
options no longer are treated ... computed?
CONCLUSIONS
1. A change in accounting method under IRC § 446 occurs when Taxpayer no longer treats certain
securities transactions as options and thus, stops deferring the gains, losses, income
https://www.justice.gov/epstein/files/DataSet%209/EFTA01193903.pdf
EFTA00590604Set 9
2017-01-087p1,350w
PWRW&G LLP DRAFT 94/06/40-1-701/08/2017
PRIVILEGED AND CONFIDENTIAL
Taxpayers: Leon Black and Debra Black (flaxpay
SSN:
Tax Form: 1040X
Tax Year: 2007
Statement of Reasonable Cause for Failure to Timely ... File Forms 5471, 8865 and 8858
Leon and Debra Black (the 'Taxpayers afe, husband and wife, and-are voluntarily filing the
attached Form 1040X (the "Amended Return") for the sole ... Internal Revenue
Service's (the "IRS") 2014 Delinquent International Information Return Submission
Procedures The Taxpayers have not been contacted by the IRS regarding_the_Amendes1
Return or the International Information
https://www.justice.gov/epstein/files/DataSet%209/EFTA00590604.pdf