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 […]
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

How are the 4 goals and outcomes 1 and 2 best obtained?

Taxpayers facing an egg shell tax audit should only be represented by experienced criminal tax defense counsel and the CPAs who perform via a Kovel agreement […]
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 […]