Beginning in the late 1990s, advisers at some accounting and law firms marketed the Son of BOSS transaction in various forms.
It is likely several thousand taxpayers used the shelter before 2000 when the Treasury and the Congress began taking steps to block its tax benefits.
The Home Concrete partners sued, arguing the IRS violated a three-year statute of limitations on its power to claim unpaid taxes.
[9] In the interim, the law firm that helped the Home Concrete partners set up their Son of BOSS transactions, Jenkens & Gilchrist, closed.
Despite numerous lawsuits Garza had been using Son of a boss shelters for 2 decades and has been the subject of articles highlighting his activities in Forbes and others.
On Thursday October 27, 2022 Joe B Garza was indicted on 21 charges of tax fraud and evasion in Federal District Court in Dallas, Texas.
If convicted, he faces a maximum penalty of 20 years in prison for each of the 18 counts of wire fraud, 20 years in prison for conspiracy to commit wire fraud, and three years in prison for each of 22 counts of aiding and assisting in the filing of false federal income tax returns According to the IRS, the IRS collected more than $3.7 billion from taxpayers in 2005 who voluntarily participated in a parallel civil global settlement initiative related to Son of BOSS.
https://www.justice.gov/opa/pr/dallas-attorney-charged-promoting-illegal-tax-shelter In a campaign advertisement released on August 9, 2012, incumbent President Barack Obama made specific reference to his GOP opponent Mitt Romney and Romney's presumed involvement in a Son of BOSS tax avoidance as a Marriott International board member.