There are three problems on this short essay answer.

For the first problem you are to analyze the fact pattern and set forth what tax crimes you as a DOJ attorney would recommend any and all defendants with.

The second problem deals with the same fact pattern except you are to set forth as defense counsel how you would defend against the charges you came up with for the first problem.

For the third you are to analyze the fact pattern and set forth what Non-Tax Crimes you as a DOJ attorney would recommend any and all defendants be charged with.

In your short answers to the problems, please cite the applicable statute you are recommending the defendant be charged with and reference the section, regulation, case, or other authority in support of your position; and indicate how that authority relates to your fact pattern. Please note that if the answer is not yes or no, and could be "it depends" please state what the issue is and what additional information you would need to answer the problem.

Fact Pattern 1 (for problems 1 and 2)

In January 2014, a taxpayer and his wife purchased a piece of land for $22,500 and simultaneously sold a portion of the piece for $20,000. In August 2015, the taxpayer sold another portion of the land for $27,000. He did not report the gain on either the 2014 or 2015 tax return.

The taxpayer admits the transactions were reportable, but contends that his understatement was not willful because he believed at the time that extensive repairs on a creek adjoining a piece of the land he retained might be needed and that the cost of these would wipe out the profit on the 2015 sale.

Fact Pattern 2 (for problem 3)

In January 2014, four related individuals filed more than 200 tax returns claiming first-time homebuyer tax credits to which the named taxpayer was not entitled. The tax refunds, including the falsely-claimed credit were deposited into one of 17 bank accounts owned or controlled by a member of the taxpayers family. The total amount of the refunds fraudulently claimed was $1,730, 086, and the total amount of the refunds issued was $1,364,171.