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Increased possibility of civil action in IRS investigation

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Increased possibility of civil action in IRS investigation

Bankers are analyzing financial data. To sum up the deposit and withdraw daily.

Bankers are analyzing financial data. To sum up the deposit and withdraw daily.

I make my client’s aware that most criminal investigations are certain to be followed by civil action on the subject of the investigation. Moreover, entering a guilty plea to a charge of tax evasion, by law stops a taxpayer from later contesting the issue of civil fraud, however, a plea of nolo contendere does not. For this reason, the government rarely accepts pleas of nolo contendere under these circumstances. I also counsel my client’s that receiving a grant of criminal immunity for testifying against another taxpayer will usually not function as a grant of civil immunity under the same plea agreement.

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