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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Monday, January 30, 2023

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This webinar will discuss recognizing and handling sensitive IRS examinations, known colloquially as eggshell audits, for CPAs and tax advisers. Our panel of seasoned tax attorneys will address factors that can turn an IRS exam into a criminal investigation, signs that your client may be targeted for a potential criminal examination, and responding to IRS summonses.

Faculty

David J. Warner
Tax Attorney, Shareholder & Managing Principal
Holtz, Slavett & Drabkin, APLC

Mr. Warner is a Tax Attorney and the Managing Attorney of the Orange County Office of Holtz, Slavett & Drabkin. He has over 10 years of experience practicing in all aspects of tax controversy including tax audits, collection defense, and litigation in the U.S. Tax Court, U.S. District Court, and the Court of Federal Claims. He represents taxpayers in cases involving income tax, estate tax, gift tax, employment tax, collection issues, innocent spouse, penalties, and bankruptcy tax issues. He also represents taxpayers before the California Franchise Tax Board (FTB), Department of Fee and Tax Administration (CDTFA, formerly State Board of Equalization (BOE)), and Employment Development Department (EDD). He has particular expertise in tax matters involving individuals and small businesses, the examination of partnerships and S corporations, and offshore tax compliance issues, including the Report of Foreign Bank and Financial Accounts (FBAR), civil fraud, and offshore information return penalties.

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Description

The IRS is boasting a 90.6 percent conviction rate for tax crimes investigated during its most recent fiscal year. This, coupled with the Service's additional hiring of 87,000 agents for audits, means taxpayers and their advisers should be prepared for tax examinations that could progress to criminal investigations. More worrisome than the penalties that result from these examinations is the fact that these convictions usually result in jail time. With taxpayers adding COVID fraud, cybercrimes, and erroneous Employee Retention Credit claims to the list of tax offenses, the number of criminal investigations will continue to increase.

Often a tax adviser may recognize significant, perhaps criminal, issues upfront. If so, should the taxpayer amend a prior year's returns to correct previous errors? Other times a practitioner needs to be able to recognize signs that a civil matter is being considered for criminal prosecution. Client communication is protected under attorney-client privilege, but the same communication may not be protected when it is between a client and a tax preparer. These sensitive audits present unique challenges for tax professionals.

Listen as our panel of former IRS trial attorneys gives practical advice on handling eggshell audits for practitioners representing clients before the IRS.

Outline

  1. Overview of federal tax crimes
  2. Factors that can make an IRS audit a sensitive audit
  3. Practical advice on handling an eggshell audit
  4. Responding to IRS summonses and grand jury subpoenas

Benefits

The panel will cover these and other key issues:

  • Indications that your client may be targeted for a criminal investigation
  • Federal tax crimes that can result in criminal convictions
  • Responding to IRS summonses and grand jury subpoenas
  • Practical advice on handling sensitive or eggshell audits

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify factors contributing to sensitive audits
  • Determine how to respond to IRS summonses
  • Decide how to handle client communications regarding eggshell audits
  • Ascertain differences between civil and criminal examinations

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of individual income taxation, including itemized deductions, individual income tax credits, net operating loss limitations including carrybacks and carryforwards.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).