(1) DECLARATION UNDER PENALTIES OF PERJURY.–Willfully makes and subscribes any return, statement, or other document, which contains or is verified by a written declaration that it is made under the penalties of perjury, and which he does not believe to be true and correct as to every material matter; or

At MSP Seals, our PTFE seals are manufactured by creating a custom blend of virgin PTFE with different fillers to add or enhance specific physical properties. The vast number of filler options have facilitated the development of numerous types of PTFE. Some of the most common fillers include:

PTFEseals

Freeman Law represents companies, executives, and individuals in regulatory and white-collar government investigations and prosecutions. We employ a proactive approach to defend vigorously and strategically position our clients. White-collar matters often involve parallel regulatory and civil proceedings. Freeman Law can navigate the complexities and collateral consequences of multiple proceedings. And when it comes to the court of public opinion, we employ ethical and strategic tactics to manage publicity. Schedule a consultation or call (214) 984-3000 to discuss your allegations and investigations concerns.

(4) REMOVAL OR CONCEALMENT WITH INTENT TO DEFRAUD.-Removes, deposits, or conceals, or is concerned in removing, depositing, or concealing, any goods or commodities for or in respect whereof any tax is or shall be imposed, or any property upon which levy is authorized by section 6331, with intent to evade or defeat the assessment or collection or any tax imposed by this title;

(B) Withholding, falsifying, and destroying records. Receives, withholds, destroys, mutilates, or falsifies any book, document, or record, or makes any false statement, related to the estate or financial condition of the taxpayer or other person liable in respect of tax;

[c] The maker did not believe the return, statement, or other document to be true and correct as to every material matter; and,

We understand that choosing the right seal supplier is crucial for your business. That’s why at MSP Seals, we go above and beyond to provide our customers with the best service and products. Our material options include Virgin PTFE and PTFE loaded with polyesters, carbon, graphite, bronze, MoS2, or any other available filler. Our team can supply custom PTFE seals in all quantities, from single pieces to high-volume production runs. Full PPAP capabilities.

I.R.C. § 7206(1) applies to “any return, statement, or other document” signed under penalties of perjury.   This statute, by its express terms, applies to “other documents.”   The government has prosecuted violations of section 7206(1)  based on the filing of a number of “other documents,” including the following:

PTFE seals often perform well in environments where other elastomers cannot. The primary benefits associated with PTFE seals include:

PTFE sealtape

(A) Concealment of property. Conceals from any officer or employee of the United States any property belonging to the estate of a taxpayer or other person liable in respect of the tax, or

[b] The return, statement, or other document contained a written declaration that it was made under the penalties of perjury;

In order to establish a violation of section 7206(1), the government must establish the following four elements beyond a reasonable doubt:

(2) AID OR ASSISTANCE.–Willfully aids or assists in, or procures, counsels, or advises the preparation or presentation under, or in connection with any matter arising under, the internal revenue laws, of a return, affidavit, claim, or other document, which is fraudulent or is false as to any material matter, whether or not such falsity or fraud is with the knowledge or consent of the person authorized or required to present such return, affidavit, claim, or document;

Federal courts have developed a number of tests to determine whether a statement is material.  Some courts have merely looked to whether the falsely reported item  must be reported correctly in order for the taxpayer to compute his or her tax correctly. Other courts, however, have looked to whether the taxpayer falsely stated an item that would have a tendency to influence the IRS and processing of the return. Other courts have held that an omitted item may be material if it should have been reported on the return, and still other courts look to whether the items constitute affirmative false injuries that have a direct bearing on income figures.

PTFE sealtemperature range

Section 7206 establishes, among other crimes, the federal tax crime of making false or fraudulent statements to the IRS, and aiding or assisting a taxpayer in making such statements.  Common violations of section 7206 include falsely inflating deductions or underreporting income. However, unlike a number of other federal tax crimes, section 7206 does not technically require that the government prove an actual tax deficiency.  This post focuses on violations of section 7206(1).

(5) COMPROMISES AND CLOSING AGREEMENTS.–In connection with any compromise under section 7122, or offer of such compromise, or in connection with any closing agreement under section 7121, or offer to enter into any such agreement, willfully–

[d] The maker falsely subscribed to the return, statement, or other document willfully, with the specific intent to violate the law.

shall be guilty of a felony and, upon conviction thereof, shall be fined* not more than $100,000 ($500,000 in the case of a corporation), or imprisoned not more than 3 years, or both, together with the costs of prosecution.

I.R.C. § 6064 creates a rebuttable presumption that the taxpayer actually signed the document. That is, under section 6064, the mere fact that an individual’s signed name appears on the return  is prima facie  evidence that he actually signed the return. United States v. Kim, 884 F.2d 189, 195 (5th Cir. 1989). Moreover, courts have found that where a person is authorized to sign another’s name, this may be sufficient even though the taxpayer did not actually sign the document.

Sealing solutions are found in almost every machine and vehicle across industries, where they serve to defend against potential component damage by external environmental factors and protect against air and fluid leakage. Seals made from polytetrafluoroethylene (PTFE seals)—also commonly referred to by the brand name Teflon®— have become popular for their inertness when interacting with most chemicals and acids, as well as an ability to handle a broad range of temperatures, pressures, and shaft speeds. Sometimes called Teflon oil seals, fluid seals, or dirt seals, PTFE seals are used in a wide variety of applications, from automotive and aerospace to pharmaceutical and food processing.

MSP Seals is ISO 9001:2015-certified and ISO 14001:2015 certified and dedicated to quality, innovation, and superior customer service. Please contact us today to see how our custom PTFE seals and other products can support your project.