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OnDemand Course

Criminal Tax Strategies for Attorneys

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.

65 minutes
Course Exam
Certificate of Completion
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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
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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

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Maine, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

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.
     
  • AR CLE 1.0
     
  • This course has been approved for 1.0 hours of CLE by the Arkansas CLE Board.
     
  • 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 Business Center, LLC. 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.
     
  • ND CLE 1.0
     
  • North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.0 hours of CLE credit.
     
  • NH MCLE 1.1
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 65 Minutes.
     
  • NM CLE 1.0
     
  • This program has been approved by the New Mexico Minimum Continuing Legal Education Board for 1.0 hours of credit.
     
  • NV CLE 1.0
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.0 CLE hours.
     
  • NY CLE 1.0 including Areas of Professional Practice 1
     
  • This course has been approved in accordance with the requirements of the New York Continuing Legal Education Board for up to a maximum of 1.0 credit hours in the area(s) of Areas of Professional Practice for 1.00 hour. Each hour may be counted only as satisfying one category of credit. Duplicate credit for the same hour of instruction is not permitted. This course qualifies for both established and newly admitted attorneys. Lorman Business Center, LLC. has a financial hardship guideline. Please contact customer service at 1.866.352.9539 for instructions on how to apply.
     
  • 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.
     
The CLE Code is ONLY a requirement when applying for CLE Credit in New York. Other states do not need to supply the CLE Code to apply for CLE credit.

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.

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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

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

Robert C. Webb

Frost Brown Todd LLP

  • Member of Frost Brown Todd LLC’s white-collar, tax, and business litigation practices in Louisville, KY
  • Represents individuals and corporations in criminal tax fraud, white-collar, and commercial litigation matters
  • 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, and was a professor at Bellarmine College, where he taught federal taxation of entities
  • Has written numerous articles regarding criminal tax and white-collar matters
  • Wrote the 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], 502-589-5400, or http://www.frostbrowntodd.com/professionals-bob-webb.html
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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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Product ID: 409692
Published 2022
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