Eggshell Audits – Keeping Your Client Out of Jail

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An eggshell audit is a civil tax audit in which the taxpayer has filed a false tax return. If the falsity comes to light then there is possibility that the IRS can refer the case for criminal investigation, and ultimately criminal prosecution. Because of the sensitivity of the issues and the potential for disastrous results, anyone involved in the audit must walk on eggshells. Hence the term "eggshell audit." 

Every tax practitioner who has represented clients for more than a few years has been approached by a scared client who has received an audit letter and who confesses that his or her tax returns were less than accurate. The failure to understand the best practices in an eggshell audit can result in the client being assessed a 75% civil fraud penalty or worse, criminal prosecution, and ultimately a trip to the federal penitentiary. 

Educational Objectives
• Who Should Handle the Audit? Accountant vs. Tax attorney
• Telltale signs that the a revenue agent is considering referring a civil case to the Criminal Investigation division
• What are the techniques the practitioner can use to minimize the risk a civil audit will turn criminal
• What to do about the filing of current tax returns during an eggshell audit 


Who would benefit most from attending this program?
Tax Attorneys, CPAs, Enrolled Agents 



Dennis Brager is a California State Bar Certified Tax Specialist and a former Senior Trial Attorney for the Internal Revenue Service's Office of Chief Counsel. In addition to representing the IRS in court, he advised the Service on complex civil and criminal tax issues. He has been named as a Super Lawyer in the field of Tax Litigation by Los Angeles Magazine every year since 2006. Mr. Brager has been quoted extensively in publications about tax matters and is a frequent speaker at national conferences. He is a former chair of both the Tax Compliance, Procedure and Litigation Committee of the Los Angeles County Bar Association, and the California State Bar, Tax Procedure and Litigation Committee. He is admitted to practice before the U.S. Supreme Court, the Ninth Circuit Court of Appeals, U.S. Claims Court, U.S. Tax Court, U.S. District Court and the U.S. Bankruptcy Court.


Ronald Marini concentrates his practice in the areas of International and Tax Law, Asset Protection, Estate Planning, and Representation before the IRS and Other Tax Authorities. During his 30 year career in International and Tax Law, he has represented a broad spectrum of International and Domestic Clients; including Fortune 500 companies, major non-U.S. businesses and numerous high net worth individuals. Mr. Marini is admitted to practice before the U.S. Tax Court.  He is also a member of the Florida Bar, member of A.I.T.C. (Association of International Tax Consultants), and the Florida International Tax Group, which is an invitational only group, of the best International Tax Advisors in the State of Florida.  Mr. Marini is able to transact business in English and Italian.