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Handling a Civil IRS Audit with Indications of Fraud (Presented by Tax Rep)

2025-09-19 13:00:00

1 hours

2025-09-19 13:00:00

1 Credits

Navigating IRS eggshell audits: identifying fraud indicators, understanding privilege protections, and strategic decisions when civil examinations reveal criminal exposure.

2025-09-19 13:00:00

1 hours

Navigating IRS eggshell audits: identifying fraud indicators, understanding privilege protections, and strategic decisions when civil examinations reveal criminal exposure.

2025-09-19 13:00:00

1 hours

1000+

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70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

Course Overview

Navigating IRS Eggshell Audits Successfully

Participants will learn to identify fraud indicators, protect client privileges, and make strategic decisions when civil audits reveal potential criminal exposure. These skills help practitioners avoid personal liability while achieving optimal client outcomes.

Fraud Identification

Recognize affirmative acts distinguishing fraud from mistakes.

Privilege Protections

Apply attorney-client and Kovel arrangement safeguards properly.

Strategic Cooperation

Determine when cooperation benefits or harms clients.

Practitioner Safeguards

Avoid criminal exposure through proper audit conduct.

Course Overview

Navigating IRS Eggshell Audits Successfully

Participants will learn to identify fraud indicators, protect client privileges, and make strategic decisions when civil audits reveal potential criminal exposure. These skills help practitioners avoid personal liability while achieving optimal client outcomes.

Fraud Identification

Recognize affirmative acts distinguishing fraud from mistakes.

Privilege Protections

Apply attorney-client and Kovel arrangement safeguards properly.

Strategic Cooperation

Determine when cooperation benefits or harms clients.

Practitioner Safeguards

Avoid criminal exposure through proper audit conduct.

Why Attend

Why this 
program matters

Understanding eggshell audits and IRS fraud indicators is critical because practitioners who fail to recognize criminal referral signs risk exposing clients to prosecution and themselves to potential malpractice or criminal liability.
90%+
IRS Criminal Investigation consistently maintains a conviction rate above 90% for cases recommended for prosecution, making early intervention essential.
$9.1B
IRS Criminal Investigation identified more than $9.1 billion in fraud during fiscal year 2024, demonstrating the scale of enforcement activity.
75%
Civil fraud penalties under IRC Section 6663 equal 75% of the tax underpayment attributable to fraud, adding substantially to financial exposure beyond criminal penalties.
66%
According to U.S. Sentencing Commission data for FY2024, 66% of tax fraud defendants received prison sentences with an average term of 15 months.

Agenda

Session 1

Identifying Key Indicators of Fraud to IRS

Session 2

Understanding Tax Client Privileges and Protections

Session 3

Accountants' Role and Limitations in Eggshell Audits

clock 1:00 pm - 1:20 pm EST

Identifying Key Indicators of Fraud to IRS

Eric L. Green

Green & Sklarz, LLC.

This session examines the critical warning signs that distinguish intentional fraud from innocent mistakes during IRS audits. Participants will learn to recognize affirmative acts of fraud such as maintaining dual books, concealing bank accounts, and omitting income, as well as indicators that a case may have been referred to criminal investigation.

Eric L. Green

Green & Sklarz, LLC.

clock 1:20 pm - 1:40 pm EST

Understanding Tax Client Privileges and Protections

Eric L. Green

Green & Sklarz, LLC.

This session explores the various legal protections available to taxpayers during audits, including attorney-client privilege, the Section 7525 accountant-client privilege, and Fifth Amendment rights against self-incrimination. Participants will understand the critical limitations of each privilege, particularly how accountant-client privilege disappears in criminal cases and why voluntarily filed documents cannot be protected.

Eric L. Green

Green & Sklarz, LLC.

clock 1:40 pm - 2:00 pm EST

Accountants' Role and Limitations in Eggshell Audits

Eric L. Green

Green & Sklarz, LLC.

This session details how accountants can effectively participate in eggshell audits while avoiding serious legal pitfalls. Topics include structuring proper Kovel arrangements to extend attorney-client privilege to accountants, conducting shadow investigations, and understanding the strategic decisions around cooperation versus non-cooperation with auditors.

Eric L. Green

Green & Sklarz, LLC.

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Key topics that will be covered

What will you learn

Attorneys will learn how to identify fraud indicators during civil IRS audits, understand privilege limitations, and navigate strategic decisions when routine examinations reveal potential criminal exposure.

What will you gain

Attorneys will gain practical knowledge for protecting clients while avoiding personal criminal exposure, including Kovel arrangement structuring and cooperation versus non-cooperation strategies.

Eggshell Audits
Civil IRS examinations where practitioners discover potential fraud issues unknown to the government.
Fraud Indicators
Affirmative acts including concealed accounts, two sets of books, and omitted income items.
Privilege Limits
Attorney-client privilege cannot protect voluntarily filed returns or documents given to government.
Kovel Arrangements
Accountants hired by attorneys gain privilege protection but cannot prepare returns under Kovel.
Criminal Referral
Warning signs include agent silence, excessive copying, and questions focusing on intent.
Strategic Decisions
Cooperation depends on whether fraud involves discoverable information like bank deposits.

What will you learn

Attorneys will learn how to identify fraud indicators during civil IRS audits, understand privilege limitations, and navigate strategic decisions when routine examinations reveal potential criminal exposure.

What will you gain

Attorneys will gain practical knowledge for protecting clients while avoiding personal criminal exposure, including Kovel arrangement structuring and cooperation versus non-cooperation strategies.

Plans

Proven CLE solutions for every legal professional

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Price
$95 – $245
Price varies based
on the course duration
of 1 to 3+ hours
$395/year
One-time purchase
Custom
based on firm size
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Number of Available Webinars 1 1,000+ 1,000+
Number of New Webinars Added Yearly Limited 500+ 500+
Earn "Live" CLE credit Included Included Included
Ability to Ask Questions During
the Presentation via a Chat Box
Included Included Included
Attend "Live" Re-Broadcasts Included Included Included
Exclusive Partner Webinars & Events Included Included
Special credits (Ethics, Elimination
of Bias, etc.)
Included Included
Instant Certificates After Completion Included Included
Personalized CLE Platform Included Included
Live Conferences Included
Bootcamps Included
Individual Purchase
Basic
Premium
Corporate CLE Plan
$95 – $245
Price varies based
on the course duration
of 1 to 3+ hours
Access type Pay per
class
Number of Available Webinars 1
Number of New Webinars Added Yearly Limited
Earn "Live" CLE credit Included
Ability to Ask Questions During
the Presentation via a Chat Box
Included
Attend "Live" Re-Broadcasts Included
Exclusive Partner Webinars & Events
Special credits (Ethics, Elimination
of Bias, etc.)
Instant Certificates After Completion
Personalized CLE Platform
Live Conferences
Bootcamps

speakers

Joe Ervin

The Law Firm for Truck Safety, LLP
image 6
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.
image 6

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Kevin Foley

Reminger Co
c728eecc0abfcd2dbf48acb129a464389888e706
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.
c728eecc0abfcd2dbf48acb129a464389888e706

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Grant H. Lawson

The Law Firm for Truck Safety, LLP
c6f6743e473668ce3f14055fd6b4bf7f8851f4ef
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.
c6f6743e473668ce3f14055fd6b4bf7f8851f4ef

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Eric L. Green

Green & Sklarz, LLC.

Eric L. Green

Green & Sklarz, LLC.

Eric L. Green is a managing partner at Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York, specializing in civil and criminal taxpayer representation before the Department of Justice Tax Division, IRS, and state Departments of Revenue Services.

Education & Credentials

Adjunct faculty at the University of Connecticut School of Law; author and lecturer of the University of Connecticut School of Business IRS Representation Certificate Program.

Recognition & Leadership

Author of The Accountant's Guide to IRS Collection, The Accountant's Guide to Resolving Tax Debts, The Accountant's Guide to Resolving Payroll Tax Debts, and The Insider's Guide to Offers-in-Compromise; columnist for CCH's Journal of Practice & Procedure.

Professional Involvement

Frequent lecturer for national organizations including Insightful Accountant, CCH, the NAEA, the NATP, the ABA Tax Section, and the Connecticut Society of CPAs.

Experience

Managing partner at Green & Sklarz LLC focusing on civil and criminal taxpayer representation; founder of Tax Rep LLC, which coaches accountants and attorneys on building IRS Representation practices; host of the weekly Tax Rep Network Podcast.

Eric L. Green

Green & Sklarz, LLC.

Eric L. Green is a managing partner at Green & Sklarz LLC, a boutique tax firm with offices in Connecticut and New York, specializing in civil and criminal taxpayer representation before the Department of Justice Tax Division, IRS, and state Departments of Revenue Services.

Education & Credentials

Adjunct faculty at the University of Connecticut School of Law; author and lecturer of the University of Connecticut School of Business IRS Representation Certificate Program.

Recognition & Leadership

Author of The Accountant's Guide to IRS Collection, The Accountant's Guide to Resolving Tax Debts, The Accountant's Guide to Resolving Payroll Tax Debts, and The Insider's Guide to Offers-in-Compromise; columnist for CCH's Journal of Practice & Procedure.

Professional Involvement

Frequent lecturer for national organizations including Insightful Accountant, CCH, the NAEA, the NATP, the ABA Tax Section, and the Connecticut Society of CPAs.

Experience

Managing partner at Green & Sklarz LLC focusing on civil and criminal taxpayer representation; founder of Tax Rep LLC, which coaches accountants and attorneys on building IRS Representation practices; host of the weekly Tax Rep Network Podcast.

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