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Criminal Tax For Accountants: What Every Practitioner Needs to Know

Author: Eric L Green

CPE Credit:  2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC

Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2026 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card

This course will review the various tax crimes, and what the government looks for when determining to prosecute a taxpayer or preparer. Emphasis will be placed on reviewing the privileges, including 5th amendment, attorney-client and accountant-client. Also a discussion of the accountant’s role in helping the attorneys prepare analysis, recreating records and looking at tax loss calculations for sentencing.

Publication Date: May 2024

Designed For
CPAs, EAs, and other tax professionals who file returns and advise clients on tax issues.

Topics Covered

  • Offenses Involving Taxation
  • Tax Crimes
  • IRC 7201 - Tax Evasion
  • IRC 7202 - Employment Tax Prosecutions
  • IRC 7202 - Willful Failure to Collect or Pay over Tax
  • IRC 7206 - Fraud and False Statements
  • IRC 7206(1) - Declaration under the Penalties of Perjury
  • IRC 7206(2) - Aiding or Assisting the Preparation of a False or Fraudulent Document
  • IRC 7212 - Attempts to Interfere with the Administration of Internal Revenue Laws
  • The New Fraud Enforcement Office
  • Administrative Summons
  • Grand Jury Subpoena
  • IRS-CI Target Letter
  • EFIN Suspension for Preparers - Automatic
  • Interview Conducted and MOIs Completed
  • Letter to DOJ Requesting Conference
  • Information vs. Indictment
  • U.S. Sentencing Guidelines
  • Adjustments, Departures, Variances

Learning Objectives

  • Identify various tax crimes
  • Recognize what the government looks for when determining to prosecute a taxpayer or preparer
  • Describe the accountant's role in helping the attorneys prepare analysis
  • Identify the clause that is generally known as the "omnibus clause"
  • Identify the IRC section that relates to willful failure to collect or pay over tax

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
A basic understanding of federal income taxation and Circular 230 rules.

Advance Preparation
None

Registration Options
Quantity
Fees
Regular Fee $70.00

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