The Williams Offshore Account Saga Continues - You Win Some, You Lose Some

I have previously blogged on the saga of Joseph B. Williams who earned income offshore and played the offshore game (offshore financial accounts and entities). Presented chronological key events in his saga are:

1. Williams earlier pled guilty to a Klein conspiracy and one count of tax evasion for the years 1993 through 2000. The conviction related to income rolling through his foreign financial accounts.

2. In the income tax phase of this saga (involving the years 1993-2000), the Tax Court earlier held that he was collaterally estopped by his conviction by plea for tax evasion for those years, so that the statute of limitations was open and he was subject to the fraud penalty. Williams v. Commissioner, T.C. Memo. 2009-81. I previously blogged on this Collateral Estoppel after Tax Evasion Conviction (4/17/09).
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