Tax Crime Junkies

Tax Crime Junkies | Episode 48 - Inside the IRS with Pietro Canestrelli (Part 2)
Show Notes:
Welcome back to Tax Crime Junkies for part two of our conversation with Pietro Canestrelli, a seasoned tax attorney with an insider’s view of the IRS. If you missed part one, make sure to go back and listen to Pietro’s jaw-dropping stories about life inside the IRS, quirky characters, and the inefficiencies that make this massive organization so fascinating.
In part two, we’re diving deeper into the world of tax law, tax crimes, and the Weekend Warrior case. Get ready for more intriguing insights, real-world examples, and stories that will make you rethink everything you thought you knew about tax law. Here’s what you can expect in this episode:
The Weekend Warrior Case: Pietro takes us through the famous Weekend Warrior Trailers v. Commissioner case. We discuss the key issues surrounding management fee deductions and the IRS’s challenge to their economic substance. What does it take to prove a business decision has a legitimate purpose beyond tax avoidance? Pietro gives us a breakdown.
The Importance of Economic Substance: We dive into the critical concept of economic substance, especially when it comes to structuring transactions that stand up to IRS scrutiny. How do tax pros ensure their clients’ moves are legally sound and not deemed abusive?
Tax Schemes and the Role of Tax Pros: Pietro offers advice for tax professionals on how to protect themselves from getting caught up in questionable tax schemes and promoter penalties. Whether it’s spotting red flags or making sure transactions are properly vetted, Pietro shares crucial tips to keep you on the right side of the law.
Pietro also discusses the changing dynamics of tax enforcement, the aggressive nature of IRS criminal investigations, and how tax professionals can navigate these challenges while providing the best service to their clients.  You can get your own copy of Pietro's book, America's Tax Defender: Stories of Taxpayers Who Fought the IRS and Won" on Amazon.  
Key Takeaways:
How the IRS assesses the economic substance of business decisions and transactions
The dangers of getting involved in abusive tax schemes and the importance of due diligence
Why maintaining good relationships with clients and IRS personnel is crucial in resolving tax disputes
Stay curious, stay vigilant, and stay on the right side of the law.
Make sure to subscribe wherever you get your favorite podcasts, and follow us on X and Instagram @TaxCrimeJunkies for more updates!

Tax Crime Junkies | Episode 47 - Inside the IRS with Pietro Canestrelli (Part 1)
Show Notes:
In this thrilling episode of Tax Crime Junkies, we dive into the mind of Pietro Canestrelli, a seasoned tax attorney who has spent years navigating both the world of tax law and the inside of the IRS. From battling audits to understanding the inner workings of the IRS, Pietro brings a wealth of experience and colorful stories that will keep you on the edge of your seat!
In part one of our conversation, Pietro gives us an inside look at the absurdities, inefficiencies, and the fascinating world of tax enforcement. You’ll hear about:
The IRS Work Culture: Pietro shares what it was like to step into the IRS as a fresh law school graduate and the frustrations of working within a system with little incentive to get work done. Get the inside scoop on what it’s like to navigate this giant bureaucracy.
Unforgettable Characters: Meet some of the quirky characters Pietro encountered inside the IRS, from The Phantom, a mysterious woman who wandered the halls, to The Walker, a man who defied dress codes by wearing running shorts. These stories give you a glimpse into the strange world behind the IRS’s serious image.
The Knife Incident: One of the most jaw-dropping stories Pietro shares is about a guy who threatened his boss with a knife—and still didn't get fired! You won’t believe how things work (or don’t work) inside the IRS.
Pietro also opens up about the lack of empathy often found within the IRS and how this impacts tax disputes, leading to mistakes that can escalate into tax crimes.
Stay tuned for part two, where we’ll dive into the Weekend Warrior case, management fee deductions, and the critical concept of economic substance. You won’t want to miss the dramatic continuation of Pietro’s story!
You can get your own copy of Pietro's book, America's Tax Defender: Stories of Taxpayers Who Fought the IRS and Won" on Amazon.  
Key Takeaways:
The bizarre and frustrating realities of working at the IRS
Insight into how empathy (or the lack thereof) can affect the outcome of tax disputes
The importance of understanding both sides of the tax law for effective representation
Stay curious, stay vigilant, and stay on the right side of the law.
Subscribe wherever you get your favorite podcasts and find us on X and instragram @TaxCrimeJunkies

Episode Summary:In this solo episode of The Fine Line Files, Dominique Molina delves into one of the most fascinating—and misunderstood—corners of tax law: what kind of income is taxable? Spoiler alert: it’s all of it. From selling lemonade to smuggling contraband, the IRS doesn’t discriminate. Every dollar earned leaves a paper trail, and Dom unpacks the legal and ethical dilemmas that arise for tax professionals navigating these murky waters.
Drawing from the infamous cases of Al Capone and Michael Miske, this episode explores how tax law can topple empires, whether built on bootlegging or black market fireworks. Dom also dives into practical advice for tax professionals: how to spot red flags, avoid liability, and balance due diligence with client relationships.
In This Episode, We Cover:
The origins of the “Al Capone Rule” and why all income, even illegal earnings, is taxable.
The IRS’s guidelines on reporting stolen property, bribes, and income from illegal activities.
How tax evasion brought down mobsters when murder charges couldn’t stick.
The ethical tightrope tax professionals walk when handling unconventional or suspicious income.
Practical steps for tax pros to identify and address red flags in client documentation.
Key Takeaways:
Reporting illegal income may not incriminate you for the crime but can protect you from tax evasion charges.
Even legitimate state-level activities, like cannabis sales, require meticulous federal compliance.
Ignoring red flags as a tax professional can lead to reputational damage, fines, or worse.
The IRS’s universal approach to taxable income reinforces the integrity of the tax system, ensuring no one—criminals or otherwise—is above the law.
Memorable Quote:“Every dollar earned has a tax story, and every tax story leaves a trail. Whether that trail leads to justice or jail depends on how closely we follow the rules.”
Connect With Us:
Website: TaxCrimeJunkies.com
Instagram & Twitter: @TaxCrimeJunkies
If You Loved This Episode:Please subscribe, leave a review, and share The Fine Line Files with your friends. Join Dom next time for another fascinating dive into the intersection of taxes, crime, and justice.
Stay Curious. Stay Vigilant. Stay On the right side of the Fine Line.

In this episode of The Fine Line Files, Dom delves into a critical yet often overlooked aspect of tax planning—verifying client claims and spotting red flags. Drawing lessons from the Mike Miske case, we explore how unchecked assumptions can lead to massive consequences for both clients and tax professionals.
Join as she discusses:
The importance of professional skepticism in tax planning.
Real-life examples of red flags that can’t be ignored.
Tips for setting boundaries with clients while maintaining a strong working relationship.
Practical strategies to protect your practice from liability.
Whether you're a seasoned tax pro or just starting out, this episode will sharpen your skills and remind you why thoroughness matters. Don’t miss this critical discussion about staying on the right side of the fine line in tax!
Follow us for more: TaxCrimeJunkies.com | @TaxCrimeJunkies on Twitter & Instagram.

In this gripping episode of Tax Crime Junkies, we delve into the dark underworld of Hawaii, where paradise meets corruption. We unravel the chilling story of Michael Miske, a once-prominent businessman whose empire of pest control, nightclubs, and fireworks concealed a criminal enterprise of racketeering, drug trafficking, tax fraud, and violence.
From fraudulent financial schemes to acts of intimidation, and even allegations of murder, Miske’s actions left a trail of devastation across the islands. We explore his rise to power, the federal investigations that spanned decades, and his ultimate downfall, marked by a guilty verdict on 13 counts earlier this year.
But the story takes an unexpected twist—just weeks before his sentencing, Miske’s death at the Federal Detention Center adds an enigmatic chapter to his already infamous legacy. Join us as we untangle the layers of this case, revealing the toll on his victims and their families, and the systemic corruption that enabled his reign.
In This Episode, We Cover:
The tragic car accident that sparked Miske’s vendetta against Jonathan Fraser.
Miske’s elaborate schemes, including nightclub skimming, structuring, and tax evasion.
The shocking use of chemical weapons against rival businesses.
Testimonies from associates and victims that ultimately sealed his conviction.
The ripple effect of his actions on Hawaii’s community and justice system.
The mystery surrounding Miske’s sudden death in federal custody.
Key Quote:“I truly believe that without Mike Miske walking around, without his authoritative figure, without the money, that Hawaii can be Hawaii again.” – Ashley Wong, girlfriend of Jonathan Fraser
Connect With Us:
Visit our website: TaxCrimeJunkies.com
Follow us on Instagram and Twitter: @TaxCrimeJunkies
If You Enjoyed This Episode:Please subscribe, leave a review, and share Tax Crime Junkies with your friends. Join us next week as we expose more loopholes that led to crime—and the truths that closed them for good.
Stay vigilant, and remember: every crime leaves a trail.

The Fine Line Files: The Importance of Internal Controls
Episode OverviewIn this episode of The Fine Line Files, Dom and Tom take a deep dive into the world of internal controls—those invisible guardians of your organization that keep operations smooth, compliant, and secure. Using the jaw-dropping story of Sandy Jenkins as a cautionary tale, they explore why internal controls are not just about bureaucracy, but a critical tool for safeguarding assets, ensuring accountability, and maintaining trust.
From defining the five interrelated components of internal control structures to discussing specific examples like segregation of duties and risk assessment, this episode equips you with a comprehensive understanding of what internal controls are and why they matter. Plus, Dom keeps things lively with her signature humor, making this heavy topic both informative and entertaining.
What You’ll Learn in This Episode
What are Internal Controls?Understand the fundamental concepts of internal controls and how they serve as the backbone of reliable financial reporting and compliance.
The Five Components of Internal Control Structures:
Control Environment
Risk Assessment
Control Activities
Information and Communication
Monitoring
Types of Internal Controls:Discover the differences between preventive vs. detective controls, hard vs. soft controls, and manual vs. automated controls.
Why Internal Controls Matter:Learn how these systems protect against fraud, safeguard assets, and help organizations operate efficiently.
Practical Tips for Implementing Internal Controls:Find out how to create an effective control environment in your department and ensure compliance.
Key Takeaways
Without strong internal controls, organizations open themselves up to financial risk, fraud, and operational inefficiency.
Internal controls are more than policies—they’re a culture and a mindset that prioritize integrity and accountability.
The tragic case of Sandy Jenkins highlights the devastating consequences of ignoring internal controls and serves as a wake-up call for businesses of all sizes.
Episode Highlights
Dom's Quip: "Segregation of duties is like a group project—you don’t want one person doing all the work, because let’s face it, we’ve all met that one slacker who ruins it for everyone."
Tom’s Insight: "Internal controls are like a seatbelt. You may not think about it when everything’s fine, but you’ll be glad you have it when something goes wrong."
Resources Mentioned
Committee of Sponsoring Organizations of the Treadway Commission (COSO) framework for internal controls.
Key risk assessment and monitoring tools used in real-world scenarios.
Connect with UsGot a question or an idea for a future episode? Reach out to us:
Website: TaxCrimeJunkies.com
Social Media: @TaxCrimeJunkies on Instagram and Twitter
Subscribe & ShareIf you enjoyed this episode, make sure to subscribe and leave a review. Don’t forget to share it with your friends and colleagues who need to know the fine line between compliance and chaos!
DisclaimerThis podcast is for informational purposes only and does not constitute legal or professional advice. Always consult with a qualified professional before making any decisions.

In this episode of Tax Crime Junkies, Dom and Tom dive into one of the most extravagant cases of embezzlement in corporate history—featuring fruitcakes, private jets, and a $16 million theft that rocked a Texas institution.
Collin Street Bakery, famous for its iconic fruitcakes, became the epicenter of a financial scandal when longtime accountant Sandy Jenkins turned the company’s funds into his personal piggy bank. For nearly a decade, Jenkins funneled millions into a lavish lifestyle of luxury cars, high-end jewelry, and beachfront vacations. How did he get away with it for so long? And what finally brought his scheme crashing down?
Join us as we uncover the sweet and sticky details of Sandy Jenkins’ infamous crime. Along the way, Dom and Tom share their thoughts—and taste buds—with a live fruitcake sampling straight from Collin Street Bakery itself. Spoiler alert: not everything about this story is a crime against taste!
What You’ll Learn in This Episode:
How an unassuming accountant masterminded an eight-year embezzlement scheme.
The red flags Jenkins ignored (and how companies can avoid similar fraud).
The incredible lengths Jenkins went to fund his lifestyle—and how it all unraveled.
How Collin Street Bakery has used this story to sweeten its reputation.
Taste Test Alert:
What better way to discuss this case than with a bite of the crime itself? Dom and Tom give their verdict on Collin Street Bakery’s world-famous fruitcake. Did it live up to the hype? Tune in to find out!
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Visit TaxCrimeJunkies.com for more episodes and resources.
Connect with us on Instagram and Twitter: @TaxCrimeJunkies
If you enjoyed this episode, please subscribe and leave a review! Don’t forget to share it with a friend who loves a juicy true-crime tale with a side of financial intrigue.

Episode Highlights:
The Burden of Proof: Why taxpayers must prove their deductions.
The Cohan Rule: How it works and its limitations.
Carlos Arizaga’s Case: A real-life example of what happens without proper records.
Practical Tips: How to document expenses, track cash payments, and avoid disallowed deductions.

Show Notes for The Fine Line Files: Management Companies – Smart Strategy or Tax Trap?
Episode Summary: In this debut episode of The Fine Line Files, Dominique Molina explores the use of management companies in tax planning. While these entities can be powerful tools for efficiency and strategic tax benefits, they can also become pitfalls if not managed correctly. Through real-life case studies, this episode uncovers where things can go wrong and how to stay compliant to avoid costly tax issues.
Key Segments:
Introduction
Introduction to the new The Fine Line Files series and its purpose: to help listeners understand and avoid tax traps.
Overview of today’s topic: the use and misuse of management companies.
Case Study 1: The Marijuana Dispensary
Story of Alternative Health Care Advocates and Wellness.
Key takeaway: Structuring a management company to sidestep tax restrictions without solid backing can lead to double disallowances.
Case Study 2: The Trucking Business
Overview of Daniel Fuhrman’s trucking operations and Grasshopper Leasing LLC.
Lesson learned: Proper documentation and agreements are essential for defending expense deductions.
Case Study 3: The Dentist’s ESOP Strategy
The failed management company and ESOP setup of Dr. Wiley M. Elick.
Key takeaway: Even with a contract, the absence of real services can dismantle a strategy.
The Importance of Substance Over Form
Explanation of why journal entries alone aren’t enough.
Practical advice on maintaining separate accounts, employing staff, and documenting services.
Practical Tips and Actionable Steps
Tips on solidifying contracts, maintaining real-time records, and issuing invoices promptly.
The importance of annual reviews and compliance monitoring.
Busting Myths and Reinforcing Compliance
Debunking common myths such as “a contract is enough” and “journal entries are proof.”
Reinforcing the need for genuine operations and documented activities.
Key Takeaways and the Human Element
Reflection on the balance between ambition and compliance.
Advice for tax professionals on becoming proactive advisors.
Conclusion
Recap of the major lessons from the episode.
Final words on the importance of transparent and well-documented strategies.
Takeaways:
Proper execution, including thorough documentation and genuine business operations, is key to using management companies effectively.
Tax professionals can offer added value by helping clients maintain compliance and mitigate risk.
The line between legitimate tax strategy and tax crime is thin but visible with the right precautions.
Call to Action: Stay tuned for future The Fine Line Files episodes, where we’ll continue to explore the traps, myths, and strategies in the world of tax planning to keep you informed and compliant.
Connect with Us:
Website: www.TaxCrimeJunkies.com
Follow us on social media:@taxcrimejunkies
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Subscribe and Review: If you enjoyed this episode, be sure to subscribe, leave a review, and share it with others who want to stay on top of tax planning insights and avoid common traps.

Description: When Sara Tokars was brutally murdered in front of her young children, the crime shocked the quiet suburban community of Cobb County, Georgia. What appeared to be a senseless act of violence unraveled into a chilling story of greed, betrayal, and murder-for-hire. At the center of it all was Fred Tokars, a well-known CPA, attorney, and former prosecutor with a dark side. In this episode, we uncover how Fred Tokars orchestrated a deadly plot that exposed a web of drug money, nightclub dealings, and tax fraud, leaving his family and community devastated. Join hosts Dominique Molina and Tom Gorczynski as they peel back the layers of this tragic case, revealing how one man's quest for power and money led to unimaginable consequences.
Episode Highlights:
Introduction to the case and Fred Tokars' background as a CPA and attorney.
The tragic events leading to the murder of Sara Tokars.
How Fred's professional facade hid his involvement in money laundering and drug deals.
The investigation that exposed Fred’s criminal network and led to his arrest.
The lasting impact on the Tokars family, especially on Sara’s sons.
Reflections on justice, crime, and the hidden motives behind financial crimes.
Key Quotes:
“In Fred’s mind, a divorce meant the unraveling of everything he had built — his secret deals, his drug connections, his entire empire.”
“Tokars wasn’t just a tax expert; he was a master manipulator, using his skills to weave a web of deception that eventually cost his wife her life.”
“It’s not just about numbers — sometimes it’s about justice.”
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