November 30, 2015

What is an eggshell audit?

An egg shell audit is a civil audit in which the return(s) under examination contain a material understatement of income, material overstatement of deductions or credits […]
November 6, 2015

How should Tax Audits be Handled by Criminal Tax Counsel?

When an underlying issue(s) in a single or set of tax or information reporting returns exists that is caused by yet undiscovered taxpayer’s potentially criminal noncompliance, […]
April 1, 2014

What are the possible outcomes of an egg shell audit?

There are generally three possible outcomes for egg shell audit; 1. The Revenue Agent does not consider the misstatements found and adjustments made during the audit […]
April 1, 2014

Effective tax defense counsels goals in an egg shell audit?

In the typical eggshell audit criminal tax defense counsel seeks to avert the emergence of a criminal investigation, by attempting to prevent a client from making […]
April 1, 2014

Why is a reverse egg shell audit dangerous for a taxpayer?

Because of recent changes in IRS internal policy, parallel investigations are on the rise and are rapidly becoming a favorite tool of the IRS. The advantages […]
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 […]