TAX FRAUD: PITFALLS REPRESENTING CLIENTS BEFORE THE IR1

Richard G. Convicer, Esq.
Eric L. Green, Esq.

The stage is set. Your client has been selected for an audit before the Examination
Division of the Internal Revenue Service. You are fully prepared to cite your client’s strengths
and concede some weaknesses. You are expecting to negotiate and compromise to reach a
settlement of the matter. The problem: an issue involving the possibility of tax fraud is raised
against your client. You continue to be straightforward and candid as you believe that
cooperation with the IRS will lead to the best result for your client. You have just made a critical
error. Why? Read on.

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