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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.



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

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

Tax Law Offices of David W. Klasing

  • 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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