Caroline D. Ciraolo was quoted in a recent Tax Notes article entitled “Tax Enforcement Announcements Are Overused, Defense Attorneys Say,” published on November 2, 2021. The article explores the intended and unintended consequences of the IRS and Justice Department publicizing enforcement efforts on tax compliance, accurate public information, and the defendant’s privacy.
The article notes:
Caroline D. Ciraolo of Kostelanetz & Fink LLP, a former head of the Justice Department Tax Division, said the announcements, especially for John Doe summonses like those authorized for Panama Offshore Legal Services or cryptocurrency exchanges, can be critical to informing taxpayers not directly named about the government’s interest in a topic. That provides those taxpayers time to address any potential tax noncompliance before IRS investigators appear with their own questions, she said. In other words, many notices not only deter taxpayers from bad behavior but also warn them about the IRS’s increased interest, she explained.
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