Caroline Rule Representative Matters

  • Persuaded the United States Attorney's Office for the District of New Jersey to charge a doctor with one count of making a false statement to the IRS, when he had in fact evaded $4.2 million in taxes over a period of years; and then persuaded the Court to sentence the doctor to probation and community service, when the advisory sentence under the United States Sentencing Guidelines was 36 months in jail.

  • Represented the former head of KPMG’s tax practice in what was then termed the largest tax fraud prosecution in United States history, and obtained dismissal of the entire indictment on grounds of prosecutorial misconduct.
  • Persuaded the Criminal Investigation function of the IRS that a client who failed to collect and pay over employment taxes for many years did not act willfully, and that the matter should be transferred back to the IRS Civil Division.

  • In connection with a very large and complicated estate, persuaded the IRS that, by placing stock certificates with bearer stock powers into a safety deposit box to which the executor had access, the decedent had made a completed gift to the executor, which saved the estate millions in estate taxes.
     
  • Negotiated a misdemeanor plea and non-jail sentence for the owner of a medical laboratory who characterized kick-backs to doctors as ordinary business expenses.
  • Quashed a prosecution for tax evasion by demonstrating that the government’s calculations of the client’s gambling earnings were based on faulty mathematics.
  • Averted the prosecution of an NBA referee who failed to declare as income the differential between the value of first class air tickets provided by the NBA (which he cashed in) and the value of economy class tickets, despite the fact that other referees were prosecuted for the same conduct.
  • Quashed the criminal prosecution of business owners who regularly, over a period of years, structured bank deposits and withdrawals to avoid banks filing currency transaction reports.
  • Obtained non-jail sentences for many clients when the United States Sentencing Guidelines called for substantial periods of incarceration.
  • Avoided numerous criminal prosecutions and crippling monetary penalties by assisting clients in making voluntary disclosures of foreign bank accounts and undeclared income earned by those accounts.
  • Persuaded the IRS that an elderly client with memory loss should not pay any penalty at all in connection with a voluntary disclosure of a foreign bank account.
  • Successfully argued that the IRS should not seek to prosecute two separate clients who failed for years to declare foreign bank accounts, records of which the government obtained from third parties, after both clients lied to IRS agents about their ownership of the accounts.