October 18, 2016

How Does the IRS Develop an Employment Tax Fraud Case from the First Indication of Fraud to a Criminal Indictment?

According to information provided by IRS employment tax auditors and examiners, the most common forms of employment tax fraud are: Willful failure to account for, collect, […]
August 1, 2016

Is Tax Fraud Likely to Be Disclosed During Divorce Proceedings?

Many soon-to-be former spouses may have an inkling of an idea that things can go seriously wrong during divorce negotiations if the process is not handled […]
February 4, 2015

Do later losses justify prior deductions?

It is a crime to knowingly overstate one’s deductions. I.R.C. Section 7201. The question posed here is whether one’s overstatement of his deductions somehow may be “justified” […]
June 18, 2013

What is the IRS burden of proof for tax fraud convictions?

When the government seeks to prove a taxpayer committed tax fraud, it need not prove a precise amount of tax due and owing. It does not […]
June 17, 2013

Difference between criminal tax evasion and civil tax fraud

A criminal tax fraud offense under IRC § 7201 and a civil tax fraud offense under IRC § 6663 are very different. As explained below, they […]