Tax Controversies: Audits, Investigations, Trials

Guide to all stages of a tax examination, investigation, litigation and prosecution -- civil or criminal.

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Print Book:2 Volumes; Looseleaf; updated annually.
ISBN: 9780820554631
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ISBN: 9781579112059
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ISBN: 9781579112059
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Product description

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

•  the recent repeal of TEFRA partnership entity-level audit rules; this reform will have a substantial impact on IRS audits of partnerships and partners.

•  an analysis of IRC § 7345, which authorizes the Secretary of State to revoke the passport of a U.S. citizen who, as certified by the IRS Commissioner, owes a seriously delinquent tax debt.

•  the latest on the quickly developing law as it relates to the search and seizure of electronic evidence from the many electronic devices used in everyday life.

•  the DOJ’s new pilot program that allows a company to receive credit for reporting and remediating its own violations under the Foreign Corrupt Practices Act.

•  the latest developments in the DOJ’s ongoing crusade against undeclared foreign bank accounts.

•  FinCEN’s new Beneficial Ownership Rules that will apply to domestic financial institutions requiring that they identify the beneficial owners of accounts held in the name of legal entities.

•  the effect of a criminal conviction on the statute of limitations for civil assessment and collection.

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

•  Sample jury charges;

•  Over 25 important IRS forms;

•  A wide selection of Civil and Criminal litigation forms.

Table of Cases and Statutes are also provided.

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Table of contents

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 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 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