Sometimes an audit goes from bad to worse and IRS Criminal Investigation becomes involved.  This course will examine the signs of when an audit is turning criminal and a makeup of the departments and organizations involved. We will discuss the sources of criminal tax cases, the evaluation and investigation of such cases, and the referral process for the prosecution of such cases. 

We will cover strategies available at each stage to avoid a criminal trial, as well as crucial points for practitioners to know about the limits of practitioner/client privilege, and what responsibilities are inherent.