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Eggshell Audits: Protecting Your Client in a Criminal Examination

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 practitioner's knowledge or participation. Practitioners that do not recognize (or simply ignore) when it's time to punt a client's representation over to competent criminal tax counsel expose themselves to professional discipline for ignoring the inherent conflicts of interest where a client's needs to avoid prosecution are ordinarily in polar opposition to the practitioner's 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.

Runtime: 99 minutes
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Why Lorman?

Over 31 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

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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More Program Information

Why Lorman?

Over 31 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 Webinar

This course was last revised on December 20, 2017.

Call 1-866-352-9540 for further credit information.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

Audio & Reference Manual

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • GA CLE 1.7
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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More Program Information

Why Lorman?

Over 31 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

David W. Klasing, Esq.,M.S.-Tax CPA

David W. Klasing, Esq.,M.S.-Tax CPA

Tax Law Offices of David W. Kasing

  • Owner of the Tax Law Offices of David W. Klasing
  • A dually licensed tax attorney and CPA, his practice emphasizes all aspects of civil and criminal tax defense representation
  • Regularly presents seminars and workshops on numerous civil and criminal, domestic and international tax topics to attorneys and CPA’s across the nation
  • Written several publications related to the areas of civil and criminal tax controversy
  • Can be contacted at 949 681-3502, [email protected] or on Twitter® @dwklasing
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Why Lorman?

Over 31 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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Product ID: 401190
Published 2017
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