Tax Controversies: Audits, Investigations, Trials

Author: Robert S. Fink (Author)
Guide to all stages of a tax examination, investigation, litigation and prosecution -- civil or criminal.
Product Format Details Qty
Print Book: 2 Volumes; Looseleaf; updated annually.
$4,204.00
In Stock ISBN: 9780820554631

Guide to all stages of a tax examination, investigation, litigation and prosecution -- civil or criminal -- including the following:

  • A discussion of the final regulations regarding the tax controversies that can be brought before the Independent Office of Appeals.
  • A new chapter on Tax Litigation that covers refunds versus protests, benefits and burdens of Tax Court versus Federal District Court, choosing between a Federal District Court and Claims Court, involvement of the U.S. Department of Justice, pretrial procedures, and much more.
  • Notice of Third-Party Summons and Taxpayer’s Right of Intervention, including discussion of Proposed Treasury Regulations Section 301.7602-2(d)(5), which provides exceptions to the 45-day advance notice requirement.
  • Use of the Freedom of Information Act in Tax Litigation that discusses the updated procedures for submitting a Freedom of Information Act request.
  • A new chapter on Bankruptcy and the IRS that covers the Bankruptcy process, Bankruptcy Court determinations of income tax, inter-agency jurisdiction and settlement authority between the IRS and the Department of Justice, determining tax lien priorities, attorney’s fees recovery, debt forgiveness, and includes Practice Tips, and much more.
  • The various methods of proof, including the direct and indirect method and information from the recently updated IRM 9.5.9 Methods of Proof.

Volume 2 augments these discussions by providing a useful collection of valuable source material, including:

  •  Sample jury charges;
  •  Important IRS forms;
  •  A wide selection of Civil and Criminal litigation forms.

Tables of Cases and Statutes and an Index are also provided.

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Volume 1

Chapter 1: Tax Examinations
Chapter 2: Appeals Office and Tax Court Procedure
Chapter 3: Assessments and Collection
Chapter 4: Tax Preparers and Practitioners
Chapter 4A: Tax Litigation
Chapter 5: Criminal Investigations
Chapter 6: Criminal Administrative Review
Chapter 7: Summons Power
Chapter 8: Grand Jury
Chapter 9: Search and Seizure
Chapter 10: Fifth Amendment Right Against Self-Incrimination
Chapter 11: Privileged Communications
Chapter 12: Use of the Freedom of Information Act in Tax Litigation
Chapter 13: Criminal and Civil Penalty Issues Relating to the Corporation
Chapter 14: Voluntary Disclosure
Chapter 15: Civil Penalties
Chapter 15A: Innocent Spouse Relief
Chapter 15B: Bankruptcy and the IRS
Chapter 16: Criminal Charges
Chapter 17: The Bank Secrecy Act and the Foreign Account Tax Compliance Act (FATCA)
Chapter 17A: Money Laundering
Chapter 18: Asset Forfeiture
Chapter 19: Methods of Proof
Chapter 20: Defenses
Chapter 21: Sentencing
Chapter 22: Collateral Consequences of a Criminal Tax Conviction

Volume 2

Appendix I: Jury Charges
Appendix II: Civil Litigation Forms
Appendix III: Internal Revenue Service Forms
Appendix IV: Criminal Litigation Forms

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