IRS Criminal Tax Stamford CT: What causes an IRS audit to be referred for criminal prosecution in Stamford, CT and elsewhere?

Education & Training with Tax Rep LLC

We frequently represent taxpayers before the IRS during routine audits in Stamford, Connecticut, as well as criminal tax investigations and eggshell audits (civil audits where tax fraud exists but the IRS has not found it yet).  I am often asked what causes an IRS examiner to send a case to the criminal investigation division (“CI”)?

The Internal Revenue Manual (“IRM”) states that an IRS tax auditor should refer the case for criminal investigation when there are “firm indications of fraud.”

Great: so what does that mean?

There are a number of items that may raise an examiner’s suspicion of tax fraud: failure to report specific income items or entire streams of income/bank accounts.  Significant underreporting of income, or overstatement of expenses may raise badges of fraud.  Also odd taxpayer behavior or refusal to provide information may also cause concern for the civil tax examiner.

I can assure you that it can be any number of items or behaviors that trigger the fraud referral to CI.

So our advice to you, in Stamford, CT or elsewhere, is if there is any reason to be concerned about something on your tax return (or maybe not on your return!), say nothing to your accountant before seeking the advise of an experienced tax attorney who handles criminal tax matters in Stamford, Connecticut and elsewhere. If you have any questions regarding IRS audits, criminal tax issues or any other IRS tax issue in Stamford, CT or any other area of Connecticut do not hesitate to contact me at (203)602-5550 or by email at

Eric L. Green, LL.M.

Convicer, Percy & Green, LLP

60 Long Ridge Road, Suite 202

Stamford, CT 06902

Ph. (203) 602-5550

Fax (03) 286-1311

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Fred Griffin Tallahassee Real Estate
Fred Griffin Real Estate - Tallahassee, FL
Licensed Florida Real Estate Broker

Eric, you stated, "say nothing to your accountant ".

  My understanding is that there is no "Accountant-Client Privilege", and my CPA could be forced to testify against me in Court, revealing information and statements that I have given to her.

  However, if my Attorney refers me to the CPA, the conversations between me and the Accountant would then fall under Attorney-Client Privilege.

  Is my understanding correct?   Thank you in advance.

Feb 25, 2012 10:39 AM #1
Eric L. Green
Tax Rep LLC - New Haven, CT
Your IRS Tax Litigator

What you are referring to is a "Kovel" accountant, which is an accountant that is hired by the attorney and therefore under the attorney-client privilege.  They are called Kovel Accountants because of the case that states that accountants hired by attorneys are under attorney-client privilege for anything they learn from that point going forward (US. v. Kovel).

Feb 25, 2012 08:17 PM #2
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Eric L. Green

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