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 In a civil lawsuit, U.S. authorities said Harold Levine earned
more than $5 million by implementing or participating in at least 90
illegal tax schemes, in which entities he set up improperly deducted
more than $515 million in bad debt losses.
The schemes took place while Levine was a partner at the law firm
Herrick Feinstein, according to the lawsuit, which was brought by
the office of Manhattan U.S. Attorney Preet Bharara.
Levine left Herrick Feinstein in 2012 to join Moritt Hock & Hamroff,
where he chairs the firm's tax practice.
"This action demonstrates that the IRS will pursue those who cheat
the tax system no matter how sophisticated or intricate the
transactions may be," said John Dalrymple, deputy commissioner for
services and enforcement of the IRS.
 In a statement, Herrick Feinstein called Levine a "rogue partner who
concealed his activities from all other Herrick lawyers." The firm
said it demanded his resignation in 2012 after discovering the
activities alleged in the complaint and has been fully cooperating
with the IRS, in addition to filing a report with a legal
disciplinary committee and commencing its own proceeding against
him.
Neither Levine nor a representative for Moritt Hock & Hamroff
responded to requests for comment.
According to his law firm biography, Levine graduated from Lehman
College in 1979 and has law degrees from Yeshiva University and New
York University.
He worked at several firms, joining Herrick in 2002, where he became
the co-chair of the tax and personal planning department, the
lawsuit said.
According to the complaint, some of the tax shelters Levine promoted
involved the illegal avoidance of corporate income taxes on gains
received from the sale of corporate assets.
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Others involved helping real estate project owners avoid paying
taxes on gains from the sale of transferable state tax credits.
The lawsuit said Levine set up five entities that would acquire the
asset-selling corporations and eliminate their capital gains tax
using the entities' phony losses.
The 90 illegal transactions resulted in more than $129 million in
tax losses to the government, the lawsuit said.
The lawsuit seeks an order barring Levine from organizing, promoting
or selling tax shelter transactions and organizing, promoting or
selling tax shelters. Levine may also face unspecified future
penalties, Bharara said.
The case is U.S. v. Levine, U.S. District Court, Southern District
of New York, No. 14-4057.
(Reporting by Nate Raymond in New York; Editing by Andrew Hay and
Mohammad Zargham)
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