The Special Agent's Report (aka pros report) is a compilation of all the information that the government believes is relevant for a criminal tax prosecution.  It should be in the discovery file.  The PDF file is easy to navigate, but the instructions are at the very end of the file. Although the report is around 30 pages, the full PDF file will be hundreds or thousands of pages long, because every allegation is corroborated by evidence in the report.  A thorough review of the report is necessary to understand the government's evidence.

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Criminal Tax Secrets: What Every Defense Attorney Should Know

Large differences exist between a civil tax investigation and a criminal tax investigation.  Knowing these differences is important in defending taxpayers in a criminal tax investigation.  Just because someone worked for the IRS doesn't make them the best choice in assisting in criminal tax matters.  In this episode, I explain the differences and why it matters.

Badges of fraud are taxpayer behaviors that the civil side of IRS is trained to look for during their assessment and collection activities.  In this episode, I review common examples of the badges of fraud the lead to a fraud referral for a criminal tax investigation.

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When the civil side of IRS believes that a tax crime has been committed, they create a report and refer the allegations to IRS-Criminal Investigation for evaluation.  Within 10 days of receiving this file, IRS-CI meets with the civil side.  This is called a "5 Way Conference."  In this conference, certain questions are asked to help IRS-CI evaluate the referral.  In this episode, I discuss the questions that are asked and why it is important if you are representing a client in a potential fraud referral.

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IRS-Criminal Investigation has the authority to investigate tax crimes either administratively or grand jury.  Both have strengths and weaknesses for the prosecution and for the defense.  In this episode, I discuss both types of investigations, and how to evaluate them.

If you are interested in how IRS-CI evaluates its investigations, my recent book Criminal Tax Secrets is available in paperback and Kindle on Amazon.

Criminal Tax Files is a production of Nordlander CPA, PLLC.  The podcast is for informational purposes and is not legal or financial advice.  If you are interested in forensic accounting and the anti-fraud/anti-money laundering industry, the Fraud Fighter Podcast is also hosted by Robert Nordlander.  It is available on every major podcast directory.

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In this episode, I review the IRS-CI 2022 Annual Report and give some insights on the organization, including highlights of the various criminal investigations around the United States.  The 2022 Annual Report features various parts of IRS-CI and its importance in the IRS mission.  The report shows various statistics and trends about the types of cases that are being investigated, prosecuted, and the source of the investigations.  If you are unfamiliar with the mission of IRS-CI, this gives a great overview of the agency.

If you are interested in how IRS-CI evaluates its investigations, my recent book Criminal Tax Secrets is available in paperback and Kindle on Amazon.

Criminal Tax Files is a production of Nordlander CPA, PLLC.  The podcast is for informational purposes and is not legal or financial advice.  If you are interested in forensic accounting and the anti-fraud/anti-money laundering industry, the Fraud Fighter Podcast is also hosted by Robert Nordlander.  It is available on every major podcast directory.

www.nordlandercpa.com
www.robertnordlander.com

Criminal Tax Files is about when taxes and crimes meet.  The weekly podcast is hosted by Robert Nordlander, a 20 year veteran with IRS-Criminal Investigation.  The goal is to bring information about criminal tax matters.  From investigations to prosecutions or anything else in between this podcast is dedicated to the criminal tax industry.

If you like what you hear, please leave a review on your favorite podcast directory, and be sure to follow this podcast so you don't miss an episode.