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Sponsored by Lorman Education
Product ID: 409692EAU
 
Credit & Course Provided by:

Criminal Tax Strategies for Attorneys

OnDemand Webinar (65 minutes)

Gain an understanding of specific tools and techniques to be used when dealing with criminal tax for attorneys.Many practitioners do not understand what facts must be present for the IRS to criminally prosecute a taxpayer for a tax crime. Additionally, many practitioners do not understand the criminal tax statutes that the IRS uses to prosecute taxpayers for tax crimes. This topic will explain the nuts and bolts involved in a criminal tax investigation. Gain the tools and techniques practitioners should use to defend the taxpayer through the criminal tax investigation and up to the trial.

Authors

Elliott E. Lieb, CFE, Lieb Consulting Robert C. Webb, Frost Brown Todd LLC

Agenda

Understanding the IRS Criminal Investigation Division

• Types of Cases Prosecuted by the IRS CID

• Sources of CID Investigations

• What Factors Must Be Present for CID to Prosecute a Tax Case

Understanding the Title 26 and Title 18 Criminal Statutes That IRS Uses to Prosecute Taxpayers

• Commonly Used Title 26 Criminal Tax Statutes

• Title 18 Statutes Used to Prosecute Taxpayers

Distinguishing Civil Tax Avoidance From Criminal Tax Evasion

• Defining Civil Tax Avoidance

• Defining Criminal Tax Evasion

• The Supreme Court's Definition of Willfulness for a Tax Crime

• How the Government Proves a Criminal Tax Crime to a Jury

Understanding the Tools and Techniques Used by the IRS to Investigate and Prosecute Criminal Tax Crimes

• Using Documents Such as Tax Returns, Public Records, Bank Records, and CPA Work Papers to Prove a Tax Crime

• Using Testimonial Evidence Such as Third-Party Interviews and Statements Made by the Taxpayer to Prove a Tax Crime

• Using Circumstantial Evidence to Prove a Tax Crime

Understanding the Steps That a Tax Practitioner Should Take When Handling a Criminal Tax Investigation

• How the Practitioner Should Parallel the Government's Investigation

• How the Practitioner Should Work With CPAs to Prepare a Defense to the Alleged Tax Crimes

Trial Tips for Defending a Criminal Tax Case in Federal Court

• The Theory of Your Case Must Explain to the Jury Why the IRS' Report Reflects a Tax Liability That Is Higher Than the Original Tax Returns

• Do Not Allow the Government to Assassinate Your Client's Character in Front of the Jury

• Be Careful About Calling Your Own Expert Because the Government Can Replay Its Entire Case Through Your Expert Accountant