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Eggshell Audits: Protecting Your Client in a Criminal Examination - Webinar

  • ID: 4425747
  • Webinar
  • 100 pages
  • Lorman Business Center, Inc.
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Learn to define the circumstances that can create criminal tax exposure for your clients.

Many tax practitioners, as a source of revenue, routinely represent their clients in civil audits but fail to recognize (or simply ignore) when they are creating a risk of criminal prosecution for their clients by not recognizing the telltale signs that they are dealing with an Eggshell or Reverse Eggshell audit where their client may have committed income tax evasion without the tax practitioners knowledge or participation.

Practitioners that do not recognize (or simply ignore) when its time to punt a clients representation over to competent criminal tax counsel expose themselves to professional discipline for ignoring the inherent conflicts of interest where a clients needs to avoid prosecution are ordinarily in polar opposition to the practitioners need to preserve their professional reputation with the auditing tax authority. Overzealous audit representatives are also in danger of committing tax perjury or obstruction and face their own exposure if the government expects that they aided and abetted the evasion of their client...

This topic will provide effective strategies to recognize and help mitigate the inherent risks for the practitioner and their client when faced with an eggshell audit.

Learning Objectives
  • You will be able to define the circumstances that can create criminal tax exposure for your clients.
  • You will be able to describe factors to be weighed in determining the likelihood that your client is facing an eggshell or reverse egg shell audit.
  • You will be able to discuss with your client the methods of proof employed by IRS auditors and criminal investigators to prove fraud occurred.
  • You will be able to explain how a CPAEA can help assist Criminal Defense Counsel in defending a client and be under the attorneys attorney client privilege with the client.
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Do I Have to Produce My Client During an IRS Eggshell Audit?
  • The Investigative Tools Available to an IRS Agent
  • Power and Procedure Surrounding an IRS Summons
  • Clients Right to Representation Under IRC §7521(c)
What Exactly Is an Eggshell or Reverse Eggshell Audit?
  • Tax Avoidance vs. Tax Evasion - Where Is the Line Drawn?
  • What Are the Likely Signs That an Audit Has Resulted in a Referral From the Auditor to the Criminal Investigation Division of the IRS?
  • What Exposure Is Created for the Tax Professional That Prepared the Returns Under Audit or Investigation by Representing His or Her Compliance Client?
Criminal Tax Defense Basics for the Tax Professional
  • What Are the Basics of Performing as a Kovel Accountant
  • What Are the Common Methods Employed by the Criminal Investigation Division to Prove Tax Fraud Occurred?
  • How Is the Most Favorable Outcome for the Client Achieved?
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David W. Klasing, Esq., M.S.-Tax CPA Tax Law Offices of David W. Kasing
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This webinar is designed for accountants, CPAs, presidents, vice presidents, CFOs, business owners and managers, controllers, tax professionals, enrolled agents, auditors and attorneys.
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