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OnDemand Course

Criminal Tax Strategies for Attorneys

Gain an understanding of specific tools and techniques that can be used when dealing with criminal tax for attorneys.

Many practitioners do not understand what facts must be present in order 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 and the tools and techniques that practitioners should use to defend the taxpayer through the criminal tax investigation and up to the trial.

Runtime: 96 minutes
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Why Lorman?

Over 33 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 33 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, 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 24, 2019.

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

  • CA MCLE 1.5
     
  • Lorman Business Center, LLC. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • OR CLE 1.5
     
  • Approved for 1.5 CLE credits in Oregon.
     
  • WA CLE 1.5
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.5 hours of A/V credit under the Law & Legal Procedure category.
     

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 33 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

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Elliott E. Lieb, CFE

Lieb Consulting

  • IRS Criminal Investigator (Special Agent) (1969 to 1995) – Case agent, Supervisor, Assistant Division Chief, Division Chief, and other management positions in various field offices throughout the United States
  • Owns and operates Lieb Consulting (1995 to present) – 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
  • Contract instructor Multi-Jurisdictional Counter Drug Task Force Training (ONDCP), teaching Financial Investigations & Money Laundering to other Law Enforcement Agencies as well as Military personnel worldwide (1998 to present)
  • Adjunct professor, Forensic Accounting, University of Cincinnati, Graduate School of Accounting (2014 to Present) – Awarded the Dean’s List of Teaching Excellence
  • Guest speaker at many local bar association (s) and various Universities
  • B.S. degree, accounting from UNLV
  • Can be contacted at [email protected]
Robert C. Webb

Robert C. Webb

Frost Brown Todd LLC

  • 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.
  • May be contacted at 502-589-5400, [email protected], or http://www.frostbrowntodd.com/professionals-bob-webb.html
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Product ID: 405051
Published 2019
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