Joseph De Gregorio · Published in Bloomberg Tax

Financial facts.
Clear boundaries.
Better preparation.

Two Bloomberg Tax articles by Joseph De Gregorio address tax-related sentencing and disclosure questions. For defendants and families, their practical relevance begins with an accurate record and the right questions for qualified counsel.

Joseph De Gregorio, Founder and President of Sentencing Advocacy Group
Joseph De Gregorio
Founder & President
Sentencing Advocacy Group

This original SAG guide explains how those published subjects relate to factual preparation. It does not reproduce the articles or offer a tax-compliance program. Tax advice, disclosure decisions and legal strategy belong with appropriately qualified professionals.

Keep different financial questions separate

Tax Fraud Sentencing Has a Gap Defense Attorneys Are Missing

This article examines a tax-fraud sentencing issue and the importance of distinguishing the sentencing analysis from restitution questions. For a family gathering records, that distinction has a practical consequence: a number should be labeled with its source, purpose and status. An amount alleged, an amount calculated by an expert and a documented payment are not interchangeable simply because each appears in the same case file.

How this relates to SAG’s work

SAG’s work can help create an organized factual record for counsel’s review. Within an agreed engagement, that means identifying available documents, building a timeline, flagging inconsistent descriptions and keeping unresolved questions visible. Where an amount is disputed or requires technical analysis, SAG identifies the question rather than presenting a consulting summary as a legal or accounting determination. Mitigation preparation may also involve employment history, family responsibilities and documented conduct, but those materials do not resolve tax liability. The article provides a starting point for an informed discussion with counsel, not a promised reduction in a particular matter.

Read the loss-and-restitution question guide →

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Build a chronology before drawing a conclusion

Changes to IRS Disclosure Program Should Spark Compliance Checks

This July 27, 2026 commentary concerns changes to an IRS disclosure program and the need for compliance review. Disclosure rules and individual eligibility can change, so the publication date matters. A reader should ask qualified tax counsel to evaluate current requirements and the actual facts before deciding whether, when or how to make a disclosure. This page does not summarize a current eligibility test or recommend a particular filing.

How this relates to SAG’s work

For SAG, the related principle is accurate factual preparation. In a federal matter, a dated chronology and a well-labeled inventory of records can help counsel see what happened and what remains uncertain. That organizational work should preserve originals, identify the source of statements and distinguish a completed action from a proposed next step. SAG does not provide tax representation, select a disclosure route or characterize an unresolved compliance question as settled. Where a reader’s immediate need is tax advice rather than sentencing preparation, the appropriate starting point is a qualified tax attorney or other relevant licensed professional.

Explore SAG’s preparation role →

Read the original at Bloomberg Tax ↗
Publisher access may require a subscription.

The next conversation

Discuss the preparation SAG can provide.

For a federal defendant or family seeking help organizing the mitigation record, the first conversation should establish your stage, counsel’s involvement and the work needed. Share contact details first; agree on a process before sending sensitive financial or case records.

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The explanations on this page are original SAG commentary, separate from the linked publisher articles. Publication does not imply Bloomberg endorsement of SAG or its services. SAG is not a law firm and does not provide legal or tax advice. Services are agreed individually; no case outcome is guaranteed.