IRS Extends California Fire Disaster Area Deadlines Until October 15th

The IRS announced this afternoon that taxpayers in Los Angeles County impacted by the current wildfires have all tax deadlines extended until October 15th. This includes:

  • Individual and C-Corporation Tax Returns (and payments of tax) due on April 15th;
  • Partnership and S-Corporation Tax Returns (and payments of tax) due on March 17th;
  • Estate and Trust Tax Returns due (and payments of tax) on April 15th;
  • Tax-exempt Organization Returns due on May 15th;
  • First, second, and third quarter Estimated Tax Payments due on April 15th, June 16th, and September 15th; and
  • Payroll and excise tax returns due on January 31st, April 30th, and July 31st.

This extension is automatic. It’s possible this will also be extended to taxpayers in Ventura County (the “Kenneth Fire” is burning in that county).  UPDATE: Luckily, the Kenneth Fire appears to be 100% contained with minimal damage.

California’s Franchise Tax Board will conform to this extended deadline (California law mandates this).  UPDATE: Governor Newsom announced the extension on Sunday.

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Personal Tax Return Filings to Begin on January 27th

The IRS announced today that, as expected, efiling of tax returns will begin on Monday, January 27th.  Individual tax returns are due on Tuesday, April 15th.

We strongly advise efiling your tax returns (if possible), and we also strongly advise you obtain an IP PIN (an IRS Identity Protection PIN) if you have not already done so.  You can obtain one on the IRS website.  Do note that you must have an account on IRS.gov in order to obtain an IP PIN (an IRS online account requires you to use id.me).  An IP PIN prevents anyone without that PIN from efiling a return with your social security number.

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New Jersey Division of Taxation Wishes to Add More Identity Theft

One of our clients received a notice from the New Jersey Division of Taxation asking for additional documentation for a previously filed tax return (copies of W-2s, 1099s, and the federal tax return).  New Jersey gave two options for responding:

  • Email to [omitted]@treas.nj.gov
  • By mail

Is New Jersey aware of the risks of identity theft by emailing documents?  Is the Division of Taxation aware of their own guidance on thisUnder the section on “How to Prevent Identity Theft and Protect Your tax Refund” the NJ Division of Taxation helpfully notes:

Do not provide personal information through e-mail, text messaging, or social media.

Yet the Division of Taxation asked someone to email personal information.  I realize that the letter my client received is a form letter, and it’s the New Jersey Division of Taxation’s policy that’s the issue (not the specific representative my client is dealing with).  The New Jersey Division of Taxation needs to both remove the option of emailing in response to notices and add a secure website upload for responding to notices.

If a tax agency asks you to email personally confidential information, just say no.  Go to the Post Office and send the response by certified mail.

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The 2024 Tax Offender of the Year

One year, perhaps, there won’t be so many nominees for my annual Tax Offender of the Year award…but this isn’t the year.  We even have a repeat nominee (and I strongly considered giving that nominee the award).  As a reminder, to win this award you have to do more than just cheat on your taxes; it needs to be big-time cheating or a series of Bozo actions.

First, we have some dishonorable mentions:

  • The Train to Nowhere, California’s high-speed rail project, that voters were told in 2008 would cost just $9.95 billion and would create 450,000 jobs, won our 2018 award. Well, the cost keeps growing (at least $130 billion, maybe more) and there’s no opening in sight.  Yes, it’s a California project but it’s receiving federal funds (for now; I suspect that might change on January 21, 2025).
  • Joseph Schwartz of Suffern, New York, owned nursing homes and withheld payroll taxes but didn’t remit them. If you want to commit a crime that has a long-term 0% chance of success and will always be investigated, employment tax fraud is the place to go! Employees will file their W-2s, the IRS won’t see the money, and it just never works.  And this case involved $38 million in tax fraud.
  • Michael Meyer of Davie, Florida, an attorney from Davie, Florida, used his legal knowledge to create “The Ultimate Tax Plan.”  And what a plan it was!  High-income individuals could donate expensive property to charities, keep the assets for their own use through tax-free loans, and then buyback the assets at a discount!  Hmm, to donate something to charity you must actually give it to that charity (you can’t keep it or buy it back at a discount).  Did I mention that the charities were bogus?  If someone ever approaches you with a scheme like this to save money on your taxes, run (don’t walk) in the other direction!  Mr. Meyer is enjoying 8 years at ClubFed and will have to make restitution.
  • Our final dishonorable mention is local (to me).  Raul Gil owned three Casa Don Juan restaurants here in Las Vegas.  He practiced “cash and carry” for his books: he carried away the cash and gave instructions to his bookkeeper to leave it off his financial statements (which were subsequently used for preparing his tax returns).  He also instructed his accountant to provide a Profit & Loss statement that matched the falsified records, and he lied to both the IRS Revenue Agent conducting an audit and IRS Criminal Investigation.  This being Las Vegas, we’re talking millions in cash ($5.1 million) with a tax loss of $1.6 million.  Mr. Gil is spending 37 months at ClubFed and must make restitution.

From San Antonio we learn of our third place finisher, Janet Yamanaka Mello.  Ms. Mello was a financial program manager for the US Army at Fort Sam Houston.  She formed a business called “Child Health and Youth Lifelong Development” (CHYLD).  The problem was that CHYLD did only one thing: fraudulently obtain grant funds from the 4-H Military Partnership Grant Program.  Ms. Mello obtained over $108 million over six years.  As is typical, the money didn’t go toward children’s development; rather, it went for clothing, cars, real estate, and other personal items.  Of course, the $108 million didn’t make it to her tax returns.  She is spending 15 years at ClubFed.

Jack Fisher, a CPA, and James Sinnott, an attorney, finished in second place for their roles in fraudulent syndicated conservation easements.  “Using inflated appraisals, backdated documents and other sham actions, these conspirators generated more than $1.3 billion in fraudulent syndicated conservation easement tax deductions, causing hundreds of millions of dollars in losses to the U.S. Treasury,” said Stuart Goldberg, the Acting Deputy Assistant Attorney General of the Justice Department’s Tax Division.  And what a program it was! For the cost of the program, you got 4.5 times the tax write-off!  It sounds too good to be true (and it was)!  They each were sentenced to over 20 years at ClubFed and must make restitution of over $400 million each.


Back in 2022, I highlighted a scheme that (at that time) had no tax impacts:

Before I get to the winner, I want to highlight a case that unfortunately has no tax charges.  Had it had any such charges, this would be tops on my list for 2022.  Instead, this is a pure fraud case.  Karl S Greenwood pled guilty to wire fraud and money laundering related to “OneCoin” earlier this month.  Mr. Greenwood allegedly earned €2.735 billion in fraudulent profits from this scheme.  He, and alleged co-conspirator Ruja Ignatova (aka “the Cryptoqueen”) did not have a high opinion of their victims:

“In an August 9, 2014, email between Greenwood and Ignatova, Ignatova described her thoughts on the ‘exit strategy’ for OneCoin. The first option that Ignatova listed was, ‘Take the money and run and blame someone else for this . . . .’ And in a September 11, 2016, exchange with Ignatova’s brother, Konstantin Ignatov, Greenwood referred to OneCoin investors stating, ‘These ppl are idiots,’ to which Ignatov responded, ‘as you told me, the network would not work with intelligent people ;)'”

If you haven’t figured it out, OneCoin never had any value and was deliberately designed as a worthless cryptocurrency.  Well, that same scheme has now gotten tax-related charges for a participant.  Mark Scott was an attorney for a well-known international law firm.  Mr. Scott had boasted of earning “50 by 50”–that’s $50 million by the time he turned 50.  And he did!

Back in 2015, he was introduced to Ms. Ignatova. It would be one thing to get Ms. Ignatova and OneCoin as clients and provide legitimate legal advice. It’s quite another to create fake private equity investment funds in the British Virgin Islands, disguise transfers of $400 million into those funds, and then launder the funds both in the Cayman Islands and Ireland.  Mr. Scott did earn more than $50 million for his money laundering; he spent some of the funds on a Ferrari, several Porsches, and seaside homes on Cape Cod.

Unfortunately for Mr. Scott, the IRS found out about this.  He was convicted in 2019, and just sentenced to 10 years at ClubFed, a “money judgement” of over $392 million, and forfeiture of other personal items.  Yet another worthy winner of our “Tax Offender of the Year” award!


With that, I wish you and yours a Happy, Healthy, and Prosperous New Year!  We’ll see you in 2025!

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I’m Not Making This Up: BOI Is Stayed Again

I swear I’m not making this up: Tonight, the 5th Circuit Court of Appeals has reversed the previous ruling, and once again the Beneficial Ownership Information (BOI) reporting requirements of the Corporate Transparency Act (CTA) are again stayed nationally.

This so reminds me of a comedy, with our heads being forced to turn first to the left and then to the right.  In any case, while this most recent decision could be appealed to the Supreme Court, it’s far more likely nothing will happen until after the appeal is heard.

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5th Circuit Court of Appeals Stays BOI/CTA Injunction; BOI Reports Again Due January 1, 2025

Today, the 5th Circuit Court of Appeals stayed the previous ruling putting a nationwide injunction against the Corporate Transparency Act’s (CTA) Beneficial Ownership Information (BOI) reporting.  This ruling can be appealed by the plaintiffs to the Supreme Court, but it’s probable the Court would not hear such a case (instead, waiting for the case to be actually ruled)–but I’m definitely not a Supreme Court expert.  UPDATE: This may also be appealed to the entire 5th Circuit (an en banc appeal), and this has a far higher likelihood of both happening and being successful.  So there may be an additional update later this week.

What does this mean?

  1. If you had an entity in existence as of January 1, 2024, you likely need to file a BOI report on or before January 1, 2025.
  2. If you formed an entity during 2024, you likely have 90 days to file a BOI report (from date you received acknowledgment from the Secretary of State).
  3. If you form an entity in 2025, you have 30 days from date of formation to file a BOI report.

A few clients reached out to us to file their BOI returns on their behalf; I will be sending them emails about this later today or tomorrow morning.

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IRS Announces 2025 Standard Mileage Rates

The IRS announced the 2025 standard mileage rates today.  The new rates are:

  • $0.70/mile for business use (up from $0.67/mile in 2024);
  • $0.21/mile for medical purposes;
  • $0.21/mile for moving for members of the Armed Forces; and
  • $0.14/mile for charitable mileage.

The IRS announcement is here.

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Nominations Due for the 2024 Tax Offender of the Year

It’s nearly time for the award I annually give: The Tax Offender of the Year.  To qualify, the winner has to do more than cheating on his or her taxes; he or she needed to really cheat or have committed a series of Bozo-like actions.  If you have a nominee, please email me at rcfox at claytontax dot com.  Our previous winners:

2023: Lev Derman et. al.
2022: Kevin Kirton
2021: Oleg Tinkov
2020: Robert Brockman
2019: Lawrence R. Gazdick, Jr.
2018: California’s Train to Nowhere
2017: State and Local Pension Crisis
2016: Judge Diane Kroupa
2015: Kenneth Harycki
2014: Mauricio Warner
2013: U.S. Department of Justice
2012: Steven Martinez
2011: United States Congress
2010: Tony and Micaela Dutson
2009: Mark Anderson
2008: Robert Beale
2007: Gene Haas
2005: Sharon Lee Caulder

If you have a nomination, please send it to me by December 26th.

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US Appeals BOI Injunction

In a move that surprises absolutely no one, the United States has appealed the preliminary injunction issued by Judge Amos Mazzant against the Corporate Transparency Act (CTA) and Beneficial Ownership Information (BOI) reporting.  The appeal is to the Fifth Circuit Court of Appeals in New Orleans.  The Fifth Circuit can leave the injunction in place until the court rules on the appeal or suspend the injunction (most likely, the injunction will stay in place for now).  An appeal will take some time to be heard (measured in months).

There has already been one case regarding CTA/BOI reporting heard at the federal appellate level.  There are numerous lawsuits challenging the CTA/BOI reporting in courts from Oregon (where a judge denied a preliminary injunction) to Florida.  I strongly believe that some CTA/BOI reporting case will be heard by the Supreme Court in 2026 (possibly sooner if we get a quick decision on this appeal that differs from the eventual ruling in the case already heard in the Eleventh Circuit).

As of today, no one is required to file a BOI report.  You can still voluntarily file your report.

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A Miss by Trump: Billy Long as IRS Commissioner

Yesterday, President-Elect Trump announced that he would nominate former Missouri Congressman Billy Long as IRS Commissioner.  This is a nomination that should not happen, and if does occur I hope that the Senate does not “Advise and Consent” to Mr. Long as IRS Commissioner.

Before I get into my reasons, there has been commentary from the left that President-Elect Trump cannot fire FBI Director Wray or the current IRS Commissioner (Danny Werfel) because their terms have not expired.  Legally, this is incorrect.  Both Wray and Werfel are political appointees in the Executive Branch; the Executive (soon to be Trump) has the absolute constitutional right to fire any and all political appointees within the Executive Branch (the FBI is within the Department of Justice, the IRS is within the Department of the Treasury).  Yes, Director Wray has three more years of a ten-year term; however, that doesn’t prevent President Trump on January 20th firing him.  It’s even clearer for IRS Commissioner Werfel: Internal Revenue Code section 7803(d) specifically notes that IRS commissioners can be “removed at the will of the President.”

President Trump’s announcement noted, “Since leaving Congress, Billy has worked as a Business and Tax advisor, helping Small Businesses navigate the complexities of complying with the IRS Rules and Regulations.  Taxpayers and the wonderful employees of the IRS will love having Billy at the helm.”

According to an article in Tax Notes, Senator Todd Young (R-IN) liked the nomination.  Predictably, Senator Elizabeth Warren (D-MA) didn’t like it (but I doubt she would like anyone nominated by President Trump).  Joe Kristan (who is the principal writer of Eide Bailly’s tax blog) told Tax Notes, “[W]hile it’s not surprising that Trump would want his own commissioner, it is a little surprising that he didn’t find somebody from the business world who would know something about managing a large enterprise, if only to control it better.”

My reason is different.  Mr. Long’s tax background is a bit checkered: He worked for what we in the tax professional community call an “ERC Mill.”  These were the companies who had continual radio and television advertising saying everyone qualified for the Employee Retention Credit (ERC), and you can get thousands and thousands of dollars from it.  An aside: Our firm had five clients approach us about the ERC.  Only two qualified: one qualified for one quarter; the other, who was told by an ERC mill that he qualified for $125,000 in credits, qualified for about 15% of that.  The ERC mills left a very bad taste with tax professionals.  But I digress….

I did a search of the literature and cannot find anything where Mr. Long came out against these mills, or noted the issues with them.  It’s possible, of course, that he has; if I see anything that comes out in the coming days where he has noted that he erred in supporting these mills, I will quickly amend this post.

To me, working for one of these mills (which effectively scammed the American taxpayers: you and I) disqualifies Mr. Long from being the IRS Commissioner.  There have to be more qualified individuals.  Even I’m more qualified than Mr. Long!

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