Attorney Eric Green will be a panelist on a national teleconference for the American Bar Association Tax Section on July 12, 2012 entitled “Eggshell Audits: Handling IRS Examinations of Closely Held Businesses When There are Criminal Tax Issues.” The panel will review issues that arise during IRS civil audits of closely held businesses in which the revenue agent is unaware of material errors and possible fraudulent conduct with respect to the returns. The panel will discuss the fine line between cooperation and remaining silent to avoid self-incrimination, the use of Kovel accountants, the government’s use of administrative summons, and the signs that the case may have been referred for criminal investigation.
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