Articles of Interest for Criminal Tax Practitioners

I have just received a hardcopy of the Tax Practice & Procedure magazine for December 2009 - January 2010 which is dedicated to the 2009 Tax Controversy Institute.  Articles in the magazine of particular interest to criminal tax practitioners are:

Nathan J. Hochman, Everything You Wanted to Know About How to Obtain a Prosecutorial Declination of a Federal Tax Case and Were Afraid to Ask.

Scott D. Michel, Undeclared Foreign Accounts -- Voluntary Disclosures and FBARs After the IRS Settlement Initiative.

Steven Toscher and Barbara Lubin, When Penalties Are Excessive -- The Excessive Fines Clause as a Limitation on the Imposition of the Willful FBAR Penalty.

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Note to readers, I will try to identify recent articles of interest to readers of this blog and, where I can obtain permission, try to have links to the articles for reading or downloading.  If the reader comes across articles of interest to this blog, please let me know by email jack@tjtaxlaw.com.  Thanks.