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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 to be caused by fraud and thus do not discover criminal tax issues;

2. The Revenue Agent discovers misstatements that they suspect might have been caused by fraud but because of effective lawyering the agent is inclined to keep the matter purely a civil examination because of lack of proof as to criminal intent;

3. The Revenue Agent makes a referral to a technical fraud specialist so that the case will be possibly worked up for a referral to the Criminal Investigation function of the IRS (CI) for prosecution.