Today a federal court in Montana unsealed an order authorizing the Internal Revenue Service (IRS) to serve a John Doe summons on Michael Behr of Bozeman, Montana, seeking information about U.S. taxpayers who may hold offshore accounts established by Sovereign Management & Legal LTD (SML), a Panamanian entity. Specifically, the IRS is seeking records of U.S. taxpayers who, during the years 2005 to 2016, had been issued a “Sovereign Gold Card” debit card that could be used to access the funds in those accounts in such a manner as to evade their obligations under internal revenue laws. The IRS uses John Doe summonses to obtain information about possible violations of internal revenue laws by individuals whose identities are unknown.
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