The session will provide the practitioner with an understand of the implications when an audit or controversy turn to criminal implications. We will explore the differences in Civil versus Criminal proceedings, the role of the IRS Criminal investigation division and the role of the Accountant in the proceeding. The session will highlight current focus areas for the IRS, We will discuss the relationship with counsel, and the need for a Kovel Letter, as well as serving as a consulting expert versus a testifying expert.
Identify situations when potential criminal implications are present
Determine the role and need for counsel, and the forensic accountant
Distinguish current focus areas for the tax authorities