#577

REPRESENTING A CLIENT IN AN IRS EGGSHELL AUDIT


--- 1.0 AZ,CA,CO,CT,FL,ID,KY,NH,NJ,NY,NV,OR,PA,WA
--- taxation law - federal tax
--- course production date: 12/6/2017
--- presented by RONALD MARINI

RONALD MARINI
This course examines the priorities of the IRS Criminal Investigations Division and issues in representing taxpayers before and during an IRS criminal tax investigation.

Recent criminal prosecutions and the focus of the CI Division on tax practitioners are reviewed, as well as issues of indications of fraud during the civil IRS examination (eggshell audit), the limitations of the IRC 7525 accountant-client privilege.

Key course points are:
• Telltale signs that the IRS is considering referring a civil to Criminal Investigation.
• Techniques the practitioner can use to minimize the risk if a civil audit will turn criminal.
• What to do about the filing of current tax returns during an eggshell audit.


--- presented by RONALD MARINI

Ronald A. Marini concentrates his practice in the areas of Tax Law both International & Domestic, Representation before the IRS, Including: IRS Audits, IRS Appeals, IRS Collections & Tax Court Cases, Asset Protection & Estate Planning.
During his 35 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 a frequent lecturer and has authored numerous articles and several books including: “U.S. Portfolio Investments,” CCH International Tax Commentaries.

Mr. Marini is admitted to practice before the U.S. Tax Court. & U.S. District Court and is recognized as a Preeminent Lawyer (Top 5%), by Martindale–Hubbell's Bar Registry of "Preeminent Lawyers" is recognized in "Lawyers of Distinction,“ (Top 10%), is recognized as “Top-Rated Lawyers” in The Miami Herald & The American Lawyer, is recognize as “Top Lawyers” in the Daily Business Review and has an “Excellent” rating by AVVO lawyer rating service.

Also Presented by: Anita W Friedlander, Esq.

Mrs. Friedlander concentrates her practice in the areas of Tax Law both International & Domestic, Representation before the IRS, Including: IRS Audits, IRS Appeals, Collections & Tax Court Cases.

Anita has strong procedural and technical tax skills acquired during her 42 years of service with the IRS which included assignment overseas; auditing and providing tax assistance.

Prior to joining Marini & Associates, P.A. - Mrs. Friedlander was an auditor, agent, appeals officer, manager and area director handing domestic, estate, collection, and international issues and appeals.