Makin It Rain Tax Relief

Makin It Rain Tax Relief Providing IRS Tax debt resolution services to taxpayers across the US.

02/01/2026

How a Jacksonville Businessman Evaded $3.7M in Federal Taxes
Jan 26, 2026- by Jason Dinesen

Earning more than $10 million and paying zero federal income tax for over a decade is not a paperwork oops. It is a ticking clock. That clock finally ran out for Phillip Mak, a Jacksonville-area businessman who pleaded guilty to attempted tax evasion after admitting he earned substantial income between 2008 and 2020, ignored repeated IRS collection efforts, and later took deliberate steps to move money and property out of the government’s reach. For tax, accounting, audit, and finance professionals, this case is not just about unpaid taxes. It is a clean, uncomfortable example of how prolonged noncompliance evolves into criminal exposure, and how actions that look routine in isolation can be stitched together into an evasion narrative once intent enters the picture.

Years of Cash Flow and Radio Silence
According to court records and Justice Department statements, Mak earned more than $10.3 million over thirteen years as a sales representative working under contract with multiple businesses. On that income, the IRS calculated he owed roughly $3.7 million in federal income taxes. He paid none of it. This was not a missed filing or a temporary cash crunch. Mak failed to pay federal income taxes for more than a decade and filed returns for only a handful of those years. During that time, the IRS followed its standard civil playbook. Notices were sent. Payment demands escalated. Eventually, a Notice of Federal Tax Lien was filed against his property. That moment matters.

Once notices and liens are in place, knowledge is established. From a legal standpoint, the taxpayer can no longer credibly claim confusion or ignorance. From there forward, every financial decision is evaluated in a different light. Despite those warnings, Mak remained silent. By the end of 2021, IRS records showed no federal income tax paid for the entire period. What many taxpayers still view as a civil collection issue hardens when inaction turns into avoidance.

Where Things Went Sideways, Fast
The government did not turn this case criminal based solely on the dollar amount. What tipped the scale was what happened next. Between 2019 and 2021, Mak took a series of steps that prosecutors argued were designed to place assets beyond the IRS’s reach. He transferred roughly $1 million to his domestic partner. He moved ownership of his personal residence into a trust created and controlled by that same partner. He also formed a corporate entity and began routing his personal income through its bank account. On paper, none of this is illegal. People create entities. People form trusts. People transfer money to partners. These are everyday tools professionals help clients use.

The problem was timing and intent. Mak admitted that at least one of these actions was taken with the intent to evade payment of his taxes and that he knew what he was doing was unlawful. That admission is the heart of the case. Tax evasion is not about aggressive planning. It is about willfulness, knowledge of the obligation, and deliberate steps to avoid paying. His defense attorney argued that earlier failures to file were tied to mental health issues, not criminal intent. That argument may still matter at sentencing. But once asset transfers and income routing occurred after IRS enforcement had begun, prosecutors had a narrative they could prove. Mak now faces up to five years in federal prison and has agreed to pay approximately $3.8 million in restitution. IRS Criminal Investigation led the case, with the Justice Department’s Tax Division and the U.S. Attorney’s Office prosecuting.

Why This Case Hits Close to Home
This case stands out precisely because it is not exotic. There were no offshore accounts, no shell companies in distant jurisdictions, and no suitcase cash businesses. This was domestic income, domestic accounts, and planning techniques that professionals see clients ask about all the time. The government relied on timing, control, and admissions. Once the collection activity was underway, otherwise ordinary transactions were reframed as efforts to frustrate enforcement. That is a reality professionals cannot ignore. It also raises uncomfortable questions about advisor exposure. Advice given during active IRS collection is often scrutinized closely, especially if it appears to facilitate asset shielding rather than resolution.

Learnings for Professionals
• Timing changes everything: Asset transfers, trust formations, and entity structures can look neutral early on. After IRS notices and liens, they can look intentional. Same transaction, very different risk profile.
• Entities are not a magic trick: Depositing personal income into a corporate account does not change its character. Substance still controls, and routing income can invite more scrutiny, not less.
• Family transfers are not off-limits: Large transfers to spouses or partners during active tax disputes are red flags. Control, purpose, and timing matter more than labels.
• Ignoring IRS notices is playing with fire: Repeated notices and a recorded lien turn silence into evidence. At that point, nonresponse becomes part of the case file.
• Intent is built, not assumed: Criminal tax cases are rarely about one act. They are built by stacking years of conduct, enforcement actions, and financial decisions into a cohesive story.
• Sometimes you have to pump the brakes: When exposure escalates, documenting advice, setting boundaries, and referring clients to specialists is not defensive; it is protective for everyone involved.

Bottom Line
Phillip Mak’s guilty plea was not about a clever scheme. It was about a simple sequence: significant income, years of nonpayment, clear IRS enforcement, and then actions taken to keep money and property out of reach. Once intent entered the picture, the case stopped being civil. For professionals, the takeaway is straightforward. Planning without compliance is fragile. When the IRS is already in the room, every move tells a story. Make sure it is not the wrong one. If you want more real-world breakdowns like this, follow along or subscribe. These cases are not rare, and the lessons keep repeating.

This is some wisdom from my amazing Tax Pro friend Melinda Tolbert EA!! Some are obvious...Some, not so much!!Here is wh...
01/22/2026

This is some wisdom from my amazing Tax Pro friend Melinda Tolbert EA!! Some are obvious...Some, not so much!!

Here is what the IRS openly shared as high risk AI enforcement indicators.
🚩Gig workers with no records (you know who you are)
🚩Large unreported income
🚩High digital asset activity especially traders
🚩Multi year and or high income non filers
🚩Schedule C volatility and large cash flow swings
🚩Scam and fraud victims
🚩Hidden assets
🚩Multi entity structures
🚩Illegal activity

Happy New Year all!
01/14/2026

Happy New Year all!

12/05/2025
Don't be caught dead representing yourself in an audit.
11/26/2025

Don't be caught dead representing yourself in an audit.

09/09/2025

Crypto/ DeFi news:
IRS to back down on controversial broker rule
(originally appeared on TheStreet. By Anushka Basu)

As per a July 10 report by Bloomberg, the Treasury Department cut a proposed set of crypto reporting rules after Congress voted to repeal them earlier in the year.

The regulation (TD 10021, RIN 1545-BR39), outlined under Section 6045, specified how decentralized crypto exchanges, or DeFi exchanges, would report the customer transaction information to the US government for tax purposes.

This action follows Congress’s earlier repeal, through the Congressional Review Act, which overturned the revised IRS rule that broadened the definition of “broker” to include DeFi platforms.
Approved last December 2024, the rule would have treated both centralized and decentralized crypto platforms as brokers who must report customer trades to help fight tax evasion.

It had been created by the enforcement provisions of the 2021 Infrastructure Investment and Jobs Act. DeFi proponents countered that DeFi platforms have no way to capture or verify user information so compliance is not practical and is an unreasonable burden. Industry groups lobbied against the expansion, arguing it would s***f out innovation and send projects overseas.

The repeal was passed by both the Senate (70–28) and the House, an indication of strong bipartisan opposition. On April 11, President Donald Trump signed a bill reversing the expanded IRS crypto brokers which otherwise would have been a burden on developers and front-end teams.

The official withdrawal of the rule by way of the Department of the Treasury draws a line in the sand, finally recognizing that Congress intended for broker reporting to apply specifically to custodial, intermediary exchanges.

It does not preclude future rulemaking that might be specifically adapted to non custodial and decentralized entities. For now, the crypto industry sees this as a win.

08/29/2025

IRS halts layoffs and plans to bring back workers as tax season looms

by Emily Peck

The Internal Revenue Service has called off layoffs and plans to offer jobs back to some employees who took the so-called fork in the road, as the agency scrambles to staff up for tax season.

Why it matters: It's the latest sign that the White House, and DOGE, overdid their firing spree.

The IRS follows several other federal agencies that have tried to rehire terminated workers or pull back on "reduction in force," or RIF, plans.

Zoom in: Workers who took deferred resignation, and have been sitting idle for months drawing salary, are being told they can come back to work — without any repercussions.

At the same time, 50 employees in the IRS Taxpayer Experience Office learned this week that their planned firing is no longer happening, a worker inside the agency confirmed to Axios.
Government Executive first reported the changes.
"IRS has identified critical vacancies that need to be filled and is exercising its discretion to offer you the opportunity to rescind your Deferred Resignation Program/Treasury Deferred Resignation Program (DRP/TDRP) agreement," reads the text of one of the emails, reviewed by Axios, that went out to employees. (DRP is short for deferred resignation program.)
"You are invited to express your interest in rescinding DRP/TDRP agreement."
The Washington Post also reported on the email.

Zoom out: The about-face comes as the agency heads into a busy tax filing season, when it will need to adopt the many changes put in place by the "big, beautiful bill."

The White House had already asked for increased funding to hire more people to help with customer service.
The agency had also reversed course on some firings of probationary workers in May, the Post reported.
A spokesperson for the Treasury Department, which oversees the IRS, said in a statement to Axios that "we are committed to ensuring the agency is staffed appropriately to serve the American people effectively and efficiently."
"We are pleased that the administration now realizes it cannot afford to lose more of these trained, nonpartisan professionals," Doreen Greenwald, national president of the union that represents IRS workers, said in a statement.

The big picture: Earlier this summer, the agency's independent taxpayer advocate warned that the coming tax filing season was at risk given the sharp drop in staff at the agency.

The IRS lost 26% of its staff this year, going from 102,000 employees to fewer than 76,000 (accounting for those who accepted the early resignation offer but are still being paid), the advocate reported.
It went through two rounds of deferred resignations.

Between the lines: Agencies have been rehiring, canceling RIFs or posting new job listings to manage the fallout from the chainsaw approach taken in the early months of the Trump administration.

Those with specific expertise, like bird flu response workers and those who maintain the country's nuclear arsenal, were rehired after a public uproar.
Fired workers at the FDA were also called back, as the Post reported.
Other agencies, like the Social Security Administration, have reassigned staff to cover mission-critical roles or posted fresh job listings.

The initial layoff and deferred resignation process throughout the federal government was done without rationality or planning, says Max Stier, president of the Partnership for Public Service, a nonprofit that advocates to improve the federal government.

"They realize that they're getting rid of people that they actually really need."

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