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

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

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 course. 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.

Publication Date: December 2018

Designed For
All CPAs, EAs, tax preparers and anyone who prepares returns, advises clients on returns or who represents clients before the IRS

Topics Covered

  • What is an eggshell audit?
  • Parallel Proceedings
  • Privilege Issues
  • Filing Current Returns
  • Sentencing considerations
  • Business entities

Learning Objectives

  • Describe criminal tax fraud
  • Identify what a Kovel letter means
  • Recognize how to outline the IRS criminal investigation process
  • Identify key issue with respect to eggshell audits
  • Identify an activity that would be included within the cash expended column in a T-account analysis when used by an examiner
  • Differentiate court cases and how they apply to your clients
  • Identify an affirmative act of fraud
  • Recognize a likely sign of criminal referral
  • Identify a referenced goal with respect to an eggshell audit
  • Describe IRC Section 7206 pitfalls for a practitioner
  • Differentiate types of accountants generally engaged when conduct by a client could result in criminal charges being brought
  • Identify an indicator of fraud as opposed to an affirmative act of fraud
  • Identify the civil fraud penalty percent


Instructional Method

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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