Tax Law Center Blog

By Parag P. Patel, Esq. | Updated August 30, 2016

Last week, on July 28, 2016, the United States Department of Justice announced an indictment against Lacy Doyle for obstructing the administration of tax laws and filing false foreign bank account report (FBARs). Doyle was arrested in New York.

In 2003, Ms. Doyle’s father died and left an inheritance of over $4 million to Doyle. Doyle, who was appointed the executor of her father’s estate, made court filings falsely stating under penalty of perjury that the total value of her father’s estate was under $1 million when, in truth and fact, it was more than four times that amount.

Thereafter, in 2006, Doyle opened a Swiss bank account for the purpose of depositing the inheritance from her father. The new account was opened in the name of a sham foundation formed under the laws of Lichtenstein to conceal Doyle’s ownership. Doyle used a corporation to conceal from the IRS her ownership of some of the undeclared accounts and deliberately failed to report the accounts and the income generated in the accounts to the IRS.

As of December 31, 2008, the account held assets valued at approximately $3,548,380. In 2004 through 2009, Doyle “willfully” failed to report on her tax returns her interest in the undeclared accounts and the income generated in those accounts. For each of these years, Doyle also failed to file a Report of Foreign Bank and Financial Accounts (FBAR) with the IRS, as the law required her to do. Willfulness is a legal definition generally requiring knowledge of the law and intent to disobey the same.

The US Department of Justice announced “As alleged in the indictment, Lacy Doyle went to extraordinary lengths to hide millions of dollars in assets and income from the IRS in overseas bank accounts. As today’s charges make clear, my Office, and our partners at the IRS, will follow our investigations of U.S. tax law violations wherever they lead.”

The United States IRS also announced “The use of offshore bank accounts to conceal income and assets remains a very high priority for the Internal Revenue Service. IRS-Criminal Investigation has made great progress in getting access to offshore account information. We will continue to utilize the resources at our disposal to uncover U.S. taxpayers who willfully evade taxes by hiding their money out of the country.”

We expect more prosecutions of individuals failing to file FBARs in the future.

About the Author

Parag P. Patel, Esq. brings over three decades of experience to individuals and businesses facing complex tax problems. Holding advanced degrees from Georgetown University Law Center (J.D.) and New York University School of Law (LL.M. in Tax Law), the nation’s top tax programs, Mr. Patel delivers sophisticated and creative strategies in complicated federal and state audits, penalty abatements, and foreign asset/income reporting. His practice emphasizes international tax matters, specifically foreign financial account reporting (FBAR), voluntary disclosures, and penalty defense.

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