The IRS Criminal Investigation Division Special Agent

The IRS Criminal Investigation Division Special Agent

The Criminal Investigation Division of the IRS is very similar to other Federal law enforcement agencies in many respects. The group is staffed with special agents who work on tax fraud and financial crime cases.

The Criminal Investigation Process in Tax Crimes Cases

The Criminal Investigation Process in Tax Crimes Cases

Criminal tax cases are primarily handled by special agents of the Criminal Investigation (CI) function of the Internal Revenue Service (IRS), the fraud referral and related divisions of the civil IRS divisions, the Tax Division of the Department of Justice, and the U.S. Attorney offices. Criminal tax cases are then referred for prosecution by the IRS to the Department of Justice Criminal Enforcement Section (CES).

Mistake or Ignorance of Law a Valid Defense for Tax Crimes

Is Mistake or Ignorance of Law a Valid Defense for Tax Crimes?

If you are being investigated for a criminal tax offense, you might wonder what defenses you can assert to avoid prosecution or severe penalties. The defense you assert must be specifically tailored to the criminal charge being brought against you. Because the IRS must prove each element of your crime beyond a reasonable doubt, your goal in coming up with a winning defense should be to negate at least one of the elements of the offense.

Recovering Administrative Costs in Tax Appeals

Recovering Administrative Costs in Tax Appeals

At the end of the Tax Appeals process, many taxpayers wonder if they will be able to recoup certain costs incurred in dealing with the IRS. Although it may not be easy, it is actually possible to obtain administrative costs, including attorney’s fees, following an Tax Appeals process. By filing a well-timed administrative claim for administrative costs or a “qualified offer,” the taxpayer may be able to do so.

Settlement Agreement Forms For Tax Tax Appeals Cases

Settlement Agreement Forms For Tax Tax Appeals Cases

When you finally come to an agreement with the Tax Appeals Officer to settle your case, the settlement should be recorded on a particular type of written form. In general, the IRS uses one of four forms for cases settled in Tax Appeals:

Settlement of Related Cases in Tax Appeals

Settlement of Related Cases in Tax Appeals

Sometimes, a taxpayer’s case may involve issues that will impact the taxpayer for years to come. Thus, an agreement with the Tax Appeals Office can affect the taxpayer’s tax return for the current year, future years, as well as related issues on those tax returns. For this reason, it may be beneficial to both parties if consistent action is taken on both related issues.

Considerations For Making A Tax Appeals Settlement Offer

Considerations For Making A Tax Appeals Settlement Offer

If you have reached the tax appeals stage and you are considering making a settlement offer to the Tax Appeals officer, there are certain things to keep in mind. As a general rule, Tax Appeals officers will give serious consideration to any good-faith attempt to settle the matter. A nuisance-value offer will simply be ignored. If you make a good-faith offer that the Tax Appeals officer believes is unacceptable, they may counteroffer or describe some other basis upon which your settlement offer might be accepted.

How to Avoid New Issues or a Reopened Case in Tax Appeals

How to Avoid New Issues or a Reopened Case in Tax Appeals

One of the greatest concerns of a taxpayer in the tax appeal process is that the appeals officer will discover new issues to investigate or choose to reopen a closed case. In 2012, the IRS released a new set of protocols for tax appeals Officers to follow. Under the appeals Judicial Approach and Culture Program (AJAC), the IRS stressed that the job of appeals is not to raise additional issues or legal arguments (1).

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