Identify indicators of tax fraud/evasion and abusive tax schemes to protect your employers, your clients, and yourself.
Many lawyers and CPAs do not understand the difference between civil tax avoidance and criminal tax evasion and the factors the IRS will use to determine whether a case is criminal or civil. This presentation will explain how the IRS determines whether actions by a taxpayer cross the line and become criminal and how, when, and why the IRS criminally prosecutes some taxpayers and only assesses civil penalties against others. We will discuss the criminal statutes that the IRS uses to prosecute taxpayers for the positions they take on their tax returns. The difference between these two important concepts directly connects to the intent of the taxpayer. Legitimate attempts to minimize tax requirements are a common practice but be advised that the IRS has a good handle on what is okay under the law and what goes over the line. A better understanding of avoidance vs. evasion will assist you and your clients to stay on the good side of the IRS.
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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
IRS Compliance Experts
- Revenue Agents/Tax Auditors
- Revenue Officers
- Special Agents
- Some IRSCI Stats
- Fraud Enforcement Office
Sentencing Observations
Avoidance vs. Evasion Key
Types of Client Representation
- CPA/Accountant/Enrolled Agent
- Civil Tax Attorney
- Criminal Attorney
- Criminal Tax Attorney
IRS Civil Enforcement Goals
IRS Criminal Enforcement Goals
Where Do Criminal Cases Originate
- Investigation Sources
- Investigation New Triggers
- The Case Selection Process
Investigative Techniques
Special Agent Actions
- Activities Not Requiring Authorized Investigations
- Additional Techniques in Subject Criminal Investigations
- Grand Jury vs. Administrative Cases
- Final Reports by Investigator
- Collaterol Issues
Proof Issues
- Willfulness
- Affirmative Acts
- Technical and General Defenses
Primary Violations
- Title 26
- Title 18
- Title 31
Proving Income
Egg Shell Audits
Client Matters
- Tips
- Management
Coming Clean
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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 February 17, 2023.
Call 1-866-352-9540 for further credit information.
- AIPB 2.0
- This program is acceptable for 2.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
Enrolled Agents 2.0
- In accordance with the standards set forth in Circular 230 section 10.6, CE credits have been granted based on a 50-minute hour. This program qualifies for 2.0 Continuing Education Credit(s) for enrolled agents.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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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
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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.
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