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.
Add to Wishlist
Credit
More Program Information
Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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
Add to Wishlist
Credit
More Program Information
Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on January 31, 2022.
Call 1-866-352-9540 for further credit information.
- AK CLE 1.0
- Alaska attorneys may receive 1.0 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
- AL CLE 1.1
- This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.1 hours credit.
- Arizona CLE 1.0
- The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.0 hours toward your annual CLE requirement for the State Bar of Arizona.
- CA MCLE 1.0
- Lorman Education Services is a State Bar of California approved MCLE sponsor and this course qualifies for 1.0 CLE hours of participatory credit.
- CT CLE 1.0
- Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.0 CLE credit(s).
- GA CLE 1.0
- This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.0 CLE hours.
- MO CLE 1.3
- This course qualifies for self-study CLE credit in Missouri.
- NM CLE 1.0
- This program has been approved by the New Mexico Minimum Continuing Legal Education Board for 1.0 hours of credit.
- RI CLE 1.0
- This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.0 hours of CLE credit.
- VT CLE 1.0
- This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.0 hour(s) of CLE credit. Please note: Attorneys may only claim 12 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
- WA CLE 1.0
- This program has been approved by the Washington State Board of Continuing Legal Education for 1.0 hours of A/V credit under the Law & Legal Procedure category.
To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
Add to Wishlist
Credit
More Program Information
Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Elliott E. Lieb, CFE
Lieb Consulting
- Owns and operates Lieb Consulting
- Conducts financial fraud investigations, criminal tax defense, money laundering defense, Bank Secrecy Act defense, and other white-collar crime defense with a variety of accredited criminal attorneys, including expert witness testimony in money laundering and financial crimes
- Contract instructor Multi-Jurisdictional Counter Drug Task Force Training (ONDCP), teaching financial investigations and money laundering to other law enforcement agencies as well as military personnel worldwide
- Past IRS Criminal Investigator (Special Agent) — case agent, supervisor, Assistant Division Chief, Division Chief, and other management positions in various field offices throughout the United States
- Adjunct professor, Forensic Accounting, University of Cincinnati, Graduate School of Accounting, awarded the Dean’s List of Teaching Excellence
- Guest speaker at many local bar associations and various universities
- B.S. degree in accounting, University of Nevada, Las Vegas
- Can be contacted at [email protected] or 859-331-5432
Robert C. Webb
Frost Brown Todd LLP
- Partner at Frost Brown Todd LLP in Louisville, KY
- Seasoned veteran attorney specializing with IRS matters
- Has represented hundreds of taxpayers in civil audits and in the U.S. Tax Court involving multiple million-dollar tax disputes
- Has led the defense of federal and state criminal offenses at the investigatory, grand jury, and trial levels in such areas as criminal tax fraud, mail and wire fraud, interstate transportation of stolen goods, criminal and civil RICO, health care fraud, criminal antitrust, money laundering, gambling, and environmental matters
- Successfully represented a former Kentucky government official in a major tax fraud and mail fraud trial, as well as executives in a health care fraud and grand jury investigation
- Conducted internal investigations for public companies and has extensive experience in counseling clients on voluntary disclosure issues
- Worked at the Department of Justice in Washington, D.C., in the Civil Tax Litigation Division
- Frequently conducts presentations on tax compliance and legal strategies and previously taught federal taxation of entities at Bellarmine College
- Authored numerous articles on criminal tax and white-collar matters, including the first Criminal Tax Practice Monograph for the University of Kentucky College of Law
- LL.M. degree in taxation, Georgetown University Law Center in Washington, D.C.
- Can be contacted at [email protected] or 502-589-5400
Add to Wishlist
Credit
More Program Information
Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
All of your training, right here at Lorman.
Pay once and get a full year of unlimited training in any format, any time!
- OnDemand Courses
- Live Webinars
- MP3 Downloads
- Course Manuals
- Executive Reports
- White Papers and Articles
Additional benefits include:
- State Specific Credit Tracker
- All-Access Pass Course Concierge
Questions? Call 877-296-2169 to speak with a real person.
Access to all training products for one year
$699/year
Unlimited Lorman Training
With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!
Easy Registrations
Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.
Invest in Yourself
You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.
