Walking on Eggshells: IRS Audits When There Are Indications of Fraud (Completed)

Date: Friday, December 7, 2018
Instructor: Eric L Green
Begin Time:  9:00am Pacific Time
10:00am Mountain Time
11:00am Central Time
12:00pm Eastern Time
CPE Credit:  2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC

Learn to Spot an "Eggshell Audit" and Protect Yourself and Your Practice

Practitioners frequently represent taxpayers in civil examinations, and the approach is usually to document as much as possible and support the numbers on the return. However, things can change drastically once a practitioner becomes aware of potential tax fraud. Everything the practitioner knows about examinations suddenly goes out the window. All of your normal steps could create risk for you as the taxpayer representative. Not only is the client now at risk of criminal enforcement, but the preparer may be drawn in as well.

Experienced tax attorney Eric L. Green will guide you through the necessary precautions and problems to look for in this two-hour CPE webinar. Amongh the issues discussed will include the various indicators of fraud that the IRS looks for, IRC §7525 Accountant-Client privilege, how to use a practitioner in criminal tax cases, and potential pitfalls for both the practitioner and the taxpayer. Attorney Green will also discuss the use of Kovel letters and recent changes in the IRS investigatory process that make it more difficult to identify when a case is referred to CID.

Who Should Attend
All CPAs, EAs, tax preparers and anyone who prepares returns, advises clients on returns or who represents clients before the IRS

Topics Covered

  • Fraud Indicators
  • IRC Section 7525 Accountant-Client Privilege--and When It Doesn't Apply
  • How the Practitioner Can Participate in a Criminal Case
  • Kovel Letters
  • IRS Procedures in Criminal Cases
  • When to Engage an Attorney

Learning Objectives

  • Explain criminal tax fraud
  • Discuss what a Kovel letter means
  • Outline the IRS criminal investigation process


Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Basic understanding of federal income taxation concepts and IRS procedures and Circular 230

Advance Preparation

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