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Biggest shelter fish trial near finish

May 11, 2011

The Wall Street Journal Law Blog has an update on the criminal trial of Paul Daugerdas. Mr. Daugerdas is probably the most prominent figure targeted by federal prosecutors in the aftermath of the mass-marketing of tax shelters in the late 1990s and early part of this century. He is said to have made $95 million in fees as the brains behind now-discredited basis-shifting shelters with names like CARDS and Son of Boss.

Jack Townsend has a technical analysis of the case up today.

I have just today read the transcript for the instruction conference on 5/5/11 in the Daugerdas criminal case. Daugerdas involved the same basic pattern as the Larson and Coplan cases (previously discussed here and here). That pattern is the prosecution of the enablers but not the taxpayers (or taxpayer advisors), with even a concession that for purposes of the submission to the jury the taxpayers are not guilty of the crime of evasion. In these cases, the prosecutors trot out several redundant or just not applicable theories of liability as if they were different than criminal liability for the underlying criminal offense of tax evasion. They are not.

The TaxProf has more.

Prior Tax Update Coverage:

Tax shelter maven Daugerdas indicted

Is backdating the fatal flaw for Daugerdas?

Tags: Jenkens and Gilchrist.Paul Daugerdas.tax crime.tax shelters.