For the first problem you are to analyze the fact pattern and set forth what Tax Crimes you as a DOJ attorney would recommend any and all defendants with.

In January, 2014, taxpayer and his wife purchased a piece of land fro $22,500 and simultaneously sold a portion of the piece for $20,000.00 in August 2015, the taxpayer sold another portion of the land for $27,000.00. He did not report the gain on either the 2014 or 2015 tax return. The taxpayer admits the transactions were reportable, but contends that his understatement was not willful since he believed at the time that extensive repairs on a creek adjoining a piece of the land he retained might be needed and that the cost of these would wipe out the profit on the 2015 sale.