This program will discuss best practices when representing a Taxpayer that has committed fraud on his or her tax return. Fraud may be underreporting income, excessive business deductions, concealing assets – both domestic and international assets, structuring, misclassification of employees, failure to file correct 941s or Trust Fund issues, and many other scenarios that could lead to a civil penalty, or worse, criminal charges.
This program will provide insight and tools to assist your client navigate the delicate nature of audits that have potential fraud exposure. You will learn what disclosure to affirmatively make, and those disclosure to try and avoid. You will learn what the IRS looks for in determining whether fraud is present and how to mitigate fraud to hopefully keep the audit civil, and not criminal. We will discuss how to respond to an IRS Summons for documentation and interview of the taxpayer. And we will learn best practices when your client’s case is referred for criminal prosecution.
Adam is a tax attorney who helps businesses and individuals with tax controversies before the Internal Revenue Service (IRS) and tax planning both domestically and internationally. He also handles a variety of white collar criminal matters, both federal and state, particularly involving civil and criminal tax fraud, including tax evasion, money laundering and offshore tax compliance. Adam's knowledge of tax law is informed by his former role as a Special Assistant U.S. Attorney with the Department of Treasury's IRS.