Speakers
Michael E. Kearney
Thomas W. McNamara
Stanley W. Parry
Program
Representing a taxpayer who has committed tax fraud but who is not under criminal investigation is a complex task. Numerous "catch-22" issues arise, such as whether to file a timely current return that may call attention to a prior failure to file, or whether filing an accurate current return may highlight omitted income or false statements on prior returns. And if a fraudulent return is selected for civil audit, the taxpayer is faced with the "Hobson's choice" of choosing between admitting the fraud or committing further crimes to cover it up. Since a new return is due every year, for the average tax cheat, problems and exposure compound as each year rolls buy.
Mr. Kearney, Mr. McNamara, and Mr. Parry will discuss this challenging aspect of tax practice and how―with knowledge of IRS policies and procedures, careful attention to professional and ethical responsibilities, and a good deal of luck―it is often possible to get such taxpayers back into the system without attracting the attention of the Criminal Investigation Division.
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Related Practices
Tax
White Collar/Investigations