December 1, 2015

How to survive audit when I cheated on return being audited

There are fewer things scarier than receiving a letter from the IRS. It begins, as it always does, with those ominous words: “Dear Taxpayer.” The letter […]
April 1, 2014

Warning signs of a criminal referral from an IRS audit

A criminal referral is likely to follow a civil audit if firm indications of fraud exist in the mind of the civil auditor. Common indications of […]
April 1, 2014

What is a reverse egg shell audit?

Reverse egg shell audits are parallel and simultaneous civil and criminal investigations where essentially a criminal tax investigation is disguised as a civil audit. Reverse eggshell […]
March 25, 2014

Precautions to be taken in the pre-audit phase

The most important part of any pre-audit strategy is due diligence, which typically means identifying potential examination and litigation risks in actual and planned transactions. Steps […]
March 25, 2014

Statute of Limitations raised during a FBAR audit?

The IRS generally has six years after “the transaction with respect to which the penalty is assessed” to impose a civil penalty related to an FBAR […]
March 25, 2014

Overview of an administrative criminal investigation

For starters, administrative investigations are categorized as general investigations, primary investigations or subject to criminal investigations based upon the alleged indiscretion and the manner in which […]