tag:blogger.com,1999:blog-1519969502186924526.post1187959351835592999..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: Tax Court Finds Fraud Based, in Part, On Negative Inference from Fifth Amendment Assertion (7/31/12)Jack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-1519969502186924526.post-2076921183004972862012-08-01T08:10:22.467-05:002012-08-01T08:10:22.467-05:00You have pointed out a major dilemma that taxpayer...You have pointed out a major dilemma that taxpayers and practitioners face in a so-called "egg-shell" audit, one that could turn criminal, particularly when the agent is aware of the core facts that could make it criminal.<br /><br />Jack TownsendJackTownsendnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-44342591564991505992012-08-01T06:36:01.906-05:002012-08-01T06:36:01.906-05:00Jack
And on these lines, I presume that advising...Jack <br /><br />And on these lines, I presume that advising a client to take the Fifth during a civil audit is a difficult and crucial decision for a practitioner. At the very least it might motivate the examiner to bring in CI, even if he/she was on the fence before. On the other hand, not invoking the fifth would mean that the civil agent would have obtained potentially incriminating information.Anonnoreply@blogger.com