Lexis Nexis Tax Controversies: Audits, Investigations, Trials
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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.
Authors / Contributors
Robert S. Fink
Robert S. Fink is a partner in the New York firm of Kostelanetz & Fink, LLP, specialists in the area of civil and criminal tax litigation. Mr. Fink is the author of the two-volume treatise, Tax Controversies: Audits, Investigations, Trials (LexisNexis, 36th Rev. March 2017), the co-author of How to Defend Yourself Against the IRS (Simon & Schuster, 1985), and the co-author of You Can Protect Yourself From the IRS (Fireside, 1987, 1988). Mr. Fink also has authored numerous articles in various professional journals on the subjects of tax investigations, tax fraud and tax litigation and is a Department Editor of the Journal of Taxation. He is an Adjunct Professor at the New York University School of Law, Graduate Tax Program and was a Visiting Professor of United States tax law at the University of Peking in Beijing, China. Mr. Fink is a fellow of the American College of Tax Counsel, a nationwide lecturer via government television, teaching civil and criminal tax procedures to attorneys and agents of the Department of Justice and the Internal Revenue Service and a frequent lecturer at various tax institutes and symposia. Mr. Fink is the past Chairman of the American Bar Association Tax Section's Committee on Civil and Criminal Tax Penalties. He was the Chairman of the New York State Bar Association Tax Section's Committee on Practice, Procedure and Compliance, past Chairman of its Committee on Criminal and Civil Tax Penalties and past Chairman of its Committee on Commodities and Financial Futures. He was Chairman of the New York County Lawyers' Association's Committee on Taxation and a member of the Association's Board of Directors. Mr. Fink was a member of the Advisory Committee to the Tax Division of the United States Department of Justice and was Chairman of the Northeast Regional IRS/Bar Liaison. He has testified as an expert witness on the Internal Revenue Service's investigative powers before subcommittees of both Houses of Congress and has testified before the New York State Assembly's Ways and Means Committee on proposed state tax legislation. Due to his successful career, Mr. Fink has been the recipient of the American Bar Association's Jules Ritholz Memorial Merit Award, ''In Recognition of Outstanding Dedication, Achievement, and Integrity in the Field of Civil and Criminal Tax Controversies.'' He is listed in ''The Best Lawyers in America''; is recognized by the review board of the magazine ''New York Super Lawyers''; is the recipient of Martindale Hubbell's highest AV rating and is the recipient of the highest rating by Chambers USA, which named him a ''superstar tax fraud defender'' and ''a revered trial attorney who has made his name in civil and criminal tax and white collar criminal defense,'' and described him as being ''held in the highest regard for his litigation skill, insight into the government, and tremendous courtroom record.'' Mr. Fink holds J.D. and LL.M. degrees from New York University School of Law.
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
