Guides to Use and Posting of Comments (1/22/14)

To the Federal Tax Crimes Blog Readers:

I welcome comments on this blog.  I learn from them; readers of this blog learn from them.  So, I thought I would post some guidelines and information that will make readers use of the comments feature better.

  • Please Keep the Comments Relevant to the Blog Entry.
Most often, readers will be able to get to the comment only by first reading the blog entry.  If your comment is  not relevant to the blog entry, a number of readers may never read it.  I presume that you are posting the comment to have readers read the comment.  Hence, by posting the comment under the -- or at least a - relevant blog entry, you will have a better chance of getting the content of the comment to the largest audience.

In some cases, where the comment is wholly irrelevant, I may not approve the comment.  (See guide below on comment moderation.)  I give an example:  In 2011, I had posted a blog item on the criminal charge via information against Michael F. Schiavo.  The blog was titled A Botched Foreign Account Quiet Disclosure Draws Criminal Charges (5/19/11).  One reader posted a comment that was not related to this discussion but rather related to the administration of the 2011 OVDI.  I decided to moderate out that comment.  It was a good comment and asked a good question about the administration of the OVDI program. But it was not relevant to the topic of the blog to which the reader was trying to append the comment.  Readers concerned that their comments might be missed should keep in mind that recent comments are posted in the column at the right, even when the comments are made to older blog entries. 
  • Please Keep the Discussion Civil.
This is a blog intended to inform and engage through discussion.  

The discussion is not furthered by intemperate comments.  For the readers to whom this blog is targeted, intemperate comments will mask any value of the comments. I remind readers of Godwin's Law which deals with a subset of intemperate comments but also addressed the broader phenomenon of intemperate comments being counterproductive to discussion.  The Daily Writing Tips Blog has a good discussion of Godwin's Law, here.  Here are some excerpts of that discussion:

Mike Godwin is an American attorney and author who formulated “Godwin’s Law” in 1990 when he made the following assertion: 
As an online discussion grows longer, the probability of a comparison involving Nazis or Hitler approaches 1.
Whether or not the law means that the discussion is over once Nazis or Hitler is mentioned, the practical effect is that that is the case and readers then reject the views of the person who raised the subject of Nazis or Hitler.

So please, unless we are talking about killing people on a large scale for racial and ethnic reasons, let's avoid the Nazis and Hitler card.

And, on the broader subject, intemperate comments will rarely be received by readers in a favorable way.  Readers will pass negative judgement on the person making the intemperate comment and will not be persuaded or even particularly interested in what that person has to say.

  • Please Avoid Comments that Are Just Rants.

Rants and super-hyperbolic discussions rarely are conducive to readers.  I realize that some hyperbole is involved in presenting arguments, but please avoid going over the top on hyperbole.  For the reasons noted above, overstating a case can be a turn off that rarely achieves the goal of persuasion.
  • The Comments Are Moderated.
I do moderate the comments.  I typically will not refuse to approve a comment so long as the comment is appropriate to the discussion and not immoderately intemperate.  In other words, I will approve moderately intemperate comments that are otherwise appropriate.  But keep in mind the discussion above that cautions the phenomenon that intemperate comments are counterproductive do discussion and persuasion.  If a reader posts a comment solely to rant without informing or persuading other readers, then the posting will be counterproductive.  If, however, the reader merely wants to use moderately intemperate hyperbole to make a point, depending upon context, it may or may not be rejected by other readers.
  • Use of Disqus as the Comment Engine.

For some time I have used a third party comment engine named Disqus because the blog providers comment engine did not seem as robust as I liked for this blog.  Information on Disqus is at the web site (web site is here and the Wikipedia entry is here)

  • Posting Anonymous Emails.

Anonymous comments are formally not allowed by Disqus.  Disgus' alternative is to allow pseudonym commenting -- which requires both an email address and a user name which can be a pseudonym (note that it requires both items of information).  Disqus' empirical data shows that comments with pseudonyms are generally of higher quality that anonymous comments.  See, for example, this article here.  However, please read further, for I offer a workaround.

On the publicly accessed Federal Tax Crimes Blog, only the pseudonym for the user name appears.  So, for example, if you make your pseudonym "Catch Me If You Can," readers reviewing the blog will not be able to see the email address.  All they can see is the pseudonym "Catch Me If You Can."  Only I as the administrator can see the email address on the administration page of Disqus (i.e., it does not appear on the blog).  I encourage all readers needing or desiring anonymity to use this feature.  Those who want to be identified can give their names instead of a pseudonyms, but those who do not want to be identified can choose pseudonyms.  For each person desiring to post pseudonymically, please choose a unique pseudonym that you will use for all future comments because there is now a feature to see all comments by a commenter (at least from today forward).  You can be fanciful -- such as my "Catch Me If You Can" but make it unique and consistently use that pseudonym

Now, for those who do not want even me to see their real email address and want to post truly anonymously in a way that readers and I can't track back to you, just enter a false email address.  Try to enter one that you are pretty sure no else one has.  For example, you might choose one like the following email address:  I doubt that anyone has that email address.  Entering such a false email address and a pseudonym for the user name will permit a reader to make anonymous comments.  So, to repeat after typing in your comment and hitting the "Post as" button, enter the following (keep in mind this is  only an example; choose your own fake email and pseudonym entries when you do it):

Your Email:
Your Name:  Catch Me If You Can

Your comment will be anonymous without traceability.  For an example, see the comments at the blog here.  For those tempted to use this work around for inappropriate comments, remember that I do moderate and will not approve improper emails.

Finally, I think it works best if you use the same fake email and the same pseudonym each time.  I think that is what is required to aggregate the comments under the pseudonym.

Here are a  few other observations about Disqus' comment features:
  1. Disqus allows nesting of the replies to comments.  
  2. The Disqus features make use of javascript.  I have not a clue what that is or what it might mean in the real world, but I presume it means that browsers should be capable of using javascript. 


  1. For me the problems only occurred with Internet Explorer; with Mozilla Firefox or Google Chrome I rarely had problems.

    I notice that now comments only show "1 day ago" or similar without giving a specific date and time for when each comment was posted. Since there are many anonymous comments it used to be nice to reply to "Anonymous of 5/15/2012 at 12:45 pm"

    Thanks again for this blog and for the education I'm getting. It's immensely helpful, especially for those doing disclosures without a lawyer.

    1. I have just changed a switch in the program to have it state the absolute date / time rather than the relative date / time. I think that should make it work, but the change did not occur immmediately. So we'll wait and see. I'll keep checking back.

      Thanks for your feedback and interest in the blog.

      Jack Townsend

  2. It is still possible to post anonymously, just as before, without the workaround. It worked on May 16 at 12:20 (above) and if this gets posted, still works.

  3. You can still post on the pages (this entry above is a page rather than a blog entry). The pages are still controlled by Blogger and not by Disqus. But, the pages are limited (maximum pages are, I think, 10. So, pages are not suitable for the quantify of items I post. Moreover, presumably the 200 limit would still cause some readers not to be able to access.

    Jack Townsend

    1. And, please keep in mind that readers can still post anonymously with a fake email address. I remind you that the email address is not published except to the comment administrator. I can see it but no one else can and I can assure you I have no interest in the email addresses. Still, for those who want total anonymity (as least as total as possible on the web), use a fake email address and a pseudonym. However, I encourage commenters to use the same fake email address and pseudonym so that other readers will be able to review other comments by that person.

      Jack Townsend

    2. we are beyond the FBAR, 906 phase after paying the 25% confiscatory penalty. Can anyone guide us as to how to amend the ILLINOIS 2003-2010 tax returns? i.e. what rate of interest, any penalties, statute of limitations?? Thanks.

  4. Jack,
    Is there any way of viewing all comments in one shot for any given topic? Right now the only way of doing that is by repeatedly clicking "Load more comments" button.

  5. Jack, I want to make certain that my comment is posted to the most relevant blog entry. In this regard, is there a way to view a list or index of all your blog entries?

    1. I am not aware of a way to view the list of index of blog entries. I think the labels / key words function somewhat like an index. Also, the search feature is pretty good.

      Jack Townsend

  6. This comment has been removed by a blog administrator.

  7. OVDP penalty calculation discrepencies from FAQ's. For 3 out the the 8 year OVDP period our accounts were tax compliant, however the our agent is saying that if they were non-compliant in any year within the 8 year window, that vaule of the account will be included in the penalty calculation for all 8 years. This seem counter to the FAQ which says that tax compliant accounts me be removed from the penalty calculation. Has anyone else experienced this and have they challenged it and won. We simply think the value of a tax compliant account should not be included in the penalty calcution for the year it compliant.

  8. Anonymous, you posted this comment in the wrong place. Go to the blogs, find a relevant blog entry, and post the comment there. Your comment will then show up in recent comments and someone undoubtedly will respond.

    The comments on this page should solely relate to the subject of the page. Accordingly in about a week, I am going to delete the comment on this page., I leave it for a week only so that you can read my response and post your comment in the right place.

    Jack Townsend

  9. I've always noticed that too, anytime the discussion gets going it always seems to resort to Nazi. I just get concerned that that horrible area in time will be diminished if everything is getting compared to it. Hopefully with proper education and a little self restraint, it could be diminished.

  10. I think once people could use social media to comment, the comments have become pretty crazy. I'm glad people are writing about what is appropriate and what isn't when is comes to commenting. I don't think that lawyer need to get involved, but it could resort to something like that in the future.

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Please make sure that your comment is relevant to the blog entry. For those regular commenters on the blog who otherwise do not want to identify by name, readers would find it helpful if you would choose a unique anonymous indentifier other than just Anonymous. This will help readers identify other comments from a trusted source, so to speak.