The Internal Revenue Service is the bane of the existence of many taxpayers, and evne the most law-abiding taxpayer may have fears about an IRS audit or investigation. This remains true even after the IRS decided to be friendlier after Congressional hearings a few years ago brought out numerous horror stories about the way the IRS had treated taxpayers and ruined many businesses by the way the agency sought to recover money owed. One reason for the fears many people have is that they have only a minimal understanding of the way the IRS investigates taxpayers, the mechanisms involved, and the specific agency that does the investigating and why it institutes an investigation. Many people also fail to differentiate between the civil and criminal investigatory powers of the IRS and how they are kept separate by law. Within the structure of the IRS, the Criminal Investigation Division has its particular roles, ways of approaching the cases brought to it, laws governing its actions, and duties to find the evidence needed for prosecution in an increasingly more complex technological environment.
The Criminal Investigation Division
American taxpayers are often beset by the fear of being audited by the Internal Revenue Service (IRS), fearing that the IRS may discover some evidence of taxpayer mis-reporting and seek retribution. In such circumstances, taxpayers face the threat of a hefty monetary penalty, and the fear is that this may emerge from a routine civil tax audit. In addition, there is sometimes the threat of criminal punishment as well. When called in for an audit, then, taxpayers may fear that the true purpose of an IRS investigation is to gain evidence to support a criminal prosecution. An IRS examination may indeed commence as a civil audit, and IRS agents also may frequently use information gathered during a civil investigation to instigate criminal proceedings against unsuspecting citizens.
The agency divides the responsibility for enforcing the tax laws between its civil and criminal divisions. In a typical civil tax investigation, an IRS agent has the primary responsibility of determining the correctness of a tax return as filed. In a criminal tax investigation, on the other hand, the agent’s main objective is to determine whether the taxpayer has engaged in fraudulent tax reporting: “Interestingly, the most frequent catalyst of a criminal investigation is the civil audit itself. However, the juncture where a civil examination turns criminal is not always clear.”
Under the American legal system, there are strict constitutional safeguards to protect individuals subject to criminal investigations, leading to a concern that IRS regulations must prohibit civil agents from circumventing these safeguards by using the civil audit to gather evidence for a criminal prosecution. Most taxpayers fear a situation in which they will permit an IRS agent to examine their private books and records during the course of a routine audit, and the agent will then use this information for criminal prosecution. Because of this concern, the IRS has explicitly enacted regulations prohibiting an IRS agent from developing a criminal case against a taxpayer in this manner. Should an agent uncover evidence of criminal wrongdoing during the course of a civil audit, that agent must then refer the case to the criminal division for prosecution, keeping the two divisions separate in terms of actions and responsibilities. Still, it is true that revenue agents often gather the same evidence as their criminal division counterparts and then offer this evidence to the criminal division.
Such a fact has consequences, as a recent review of the issue notes:
These transgressions severely threaten the American voluntary tax reporting system. The present revenue collection system centers on the self-reporting and voluntary compliance of taxpayers. However, if taxpayers are uncertain as to whether tax investigations are criminal or civil in nature, they will not submit to routine tax examinations and the system of voluntary compliance will collapse. While the IRS properly requests permission to examine books and records of taxpayers to collect tax revenue, use of such information to secure evidence for criminal prosecution poses a danger to the entire system.
Taxpayers often have little recourse against such misconduct, since legislation fails to specify a remedy for violations of taxpayers’ constitutional rights even though these actions clearly violate IRS regulations.
Criminal investigations are addressed under I.R.C. [subsection] 7201, 7202, 7203, 7206, and 7212(a) of the tax code. The Examination Division investigates civil tax cases, and the Criminal Investigation Division (“CID”) investigates potential criminal violations. The latter serve two purposes, according to the Internal Revenue Manual. The first is to enforce the tax laws, and the second is to encourage voluntary compliance by setting an example of what a failure to comply might mean. The CID focuses on individuals participating in illicit activities utilizing sophisticated criminal schemes or on high-dollar financial transactions, and the IRS is also more likely to press a case against a prominent taxpayer than against a relatively obscure person. This also leaves few agents available to audit returns among the general population, which further reduces the percentage of total returns audited: “The IRS’s focus on prominent individuals and illicit activities may be insufficient to significantly enhance voluntary compliance.” (for this and other journal surveys, the data can be found in several annual reviews, often virtually identical, though listed with different authors. Presumably this is a custom for law review material.)
CID special agents in the division are responsible for investigating allegations of criminal violations under the I.R.C. And related provisions of Title 18 of the United States Code. A special agent is charged with conducting an administrative investigation when he or she is notified of a matter with the potential of criminal prosecution or that warrants further inquiry. If the special agent determines that the matter warrants prosecution, he or she prepares a special agent’s report (“SAR”) that explains the details of the investigation, its results, and the recommendations of the agent. If warranted, the matter is then referred to IRS counsel, and that person then makes the referral to the Department of Justice (“DOJ”), Tax Division or directly to the U.S. Attorneys Office. A referral to the Tax Division terminates the CID’s authority to use the administrative investigation process. The Tax Division acts under the guidance of the Assistant Attorney General and authorizes prosecution in criminal tax cases. The Tax Division also supports and coordinates tax litigation. U.S. Attorneys have responsibility for litigating criminal tax cases.
The special agents are financial investigators and serve a unique purpose in federal law enforcement. These agents have to analyze the types of sophisticated scheme to defraud the government that are common today, and to combat this, investigators require the analytical ability to wade through complex paper and computerized financial records. Because of the greater use of automation for financial records, IRS special agents are trained to recover computer evidence and can use specialized forensic technology to recover financial data even if it has been encrypted, password protected, or hidden by other electronic means.
The Chief of Criminal Investigation is in the IRS headquarters office located in Washington, DC, and the Chief directs the policies and programs for IRS Criminal Investigation nationwide.
Among the responsibilities for the Chief are the enforcement of the criminal statutes relative to tax administration and related financial crimes; violations of the Bank Secrecy Act, and the Money Laundering Control Act. The Criminal Investigation strategic plan consists of three interdependent programs: Legal Source Tax Crimes; Illegal Source Financial Crimes; and Narcotics Related Financial Crimes. The three are mutually supportive and involve utilization of all statutes within the agency’s jurisdiction, the grand jury process, and enforcement techniques to combat tax, money laundering, and currency crime violations: “Criminal Investigation must investigate and assist in the prosecution of those significant financial investigations that will generate the maximum deterrent effect, enhance voluntary compliance, and promote public confidence in the tax system.”
CID is divided into thirty-five field offices, and each field office has a Special Agent in Charge to direct, monitor, and coordinate the criminal investigation activities within that office’s area of responsibility. Each field office has several smaller posts-of-duty as well. There are specialized units for particular responsibilities, such as the High Intensity Money Laundering and Related Financial Crime Area (HIFCA) Task Forces. These were mandated in the National Money Laundering Strategy and occupy the flagship role in the nation’s efforts to disrupt and dismantle large-scale money laundering systems and organizations. This group serves to concentrate law enforcement efforts at the federal, state, and local levels for combating money laundering in high-intensity money laundering zones, whether based on drug trafficking or other crimes. These units today are located in the Northern District of Illinois (Chicago), the Northern District of California (San Francisco), and in New York/New Jersey, San Juan/Puerto Rico, Los Angeles, and a “systems HIFCA” that was designed to address cross-border currency smuggling in Texas/Arizona to and from Mexico. Each of these groups is composed of all relevant federal, state, and local enforcement authorities; prosecutors; and federal financial supervisory agencies as needed, and each works closely with the High Intensity Drug Trafficking Areas (HIDTA) and Organized Crime Drug Enforcement Task Forces (OCDETF) to focus on collaborative investigative techniques.
There are ten Fraud Detection Centers across the United States, and these are meant to detect refund fraud and to identify prevention measures. Each of these offices has a Resident Agent in Charge to direct, monitor, and coordinate operations supporting electronic and paper tax filing, and each Center performs activities that include educating Submission Processing Center and Customer Service Center personnel on fraud awareness and detection.
Criminal investigation in the agency started shortly after the Revenue Act of 1913 was passed, and that act imposed a modest tax of 1% on net incomes of individuals, estates, trusts, and corporations. In addition, another tax, or surtax, graduated from 1 to 6%, was applied to income exceeding $20,000. Over time, many laws have been passed that have changed the rates and other aspects of revenue assessment. Tax evasion was noted as early as 1919, when many serious allegations concerning alleged tax frauds were identified by the Internal Revenue Service. The agency started its first narcotics investigation of an opium trafficker in Hawaii in the early 1920’s on the basis of tax evasion. The IRS Commissioner decided to establish a group just to investigate fraud and did so on July 1, 1919, when six experienced Postal Inspectors were transferred to the Bureau of Internal Revenue as the first special agents in the Special Intelligence Unit. This first group of agents was responsible for sending numerous notorious gangsters, racketeers, and other criminal figures to prison, the most notable of whom was Public Enemy Number One, Al Capone, who was never prosecuted for his other criminal activities but who was sent to prison for tax evasion.
The IRS investigates three primary crimes: 1) Tax evasion (the intentional conduct to defeat the income tax law — like tax cheating schemes); 2) Filing a false return (tax returns containing misstatements); and 3) Failure to file a tax return. The IRS has a high success rate in that its investigations lead to successful criminal prosecution of tax crimes some 80% of the time, and about two-thirds of those charged with tax crimes plead guilty.
History Then and Now the CID has not always been as efficient as intended and has kept its failures secret to the degree possible. It was recently noted that the agency has a secret internal file called 75 Years of Criminal Investigation History 1919-1994, a 202-page report not meant for publication. An article about this report notes, “Perhaps such secrecy concerning the report reflects an IRS desire to limit access to its internal investigations. It did a lot to police itself in its early days and continues to do so today. Some of the IRS allegations against its criminal investigators are strikingly similar to what the public heard last year during Senate Finance Committee hearings on IRS abuses.”
The files show that “a large number of investigations of charges against [IRS] personnel involving attempted extortion, bribery, collusion and other irregularities.” The report also states that “many revenue officers were in league with big bootleggers and others in tax-fraud conspiracies.” In 1924, there was an all-time high of 535 investigations against IRS personnel, and this dropped to an all-time low of 33 in 1932. The files say that this was because part of the agency’s mission is to “clean house of dishonest employees.” In 1936, though, the number of charges involving IRS personnel shot up to 175. It is also noted that the CID had about a 50% conviction record against their own employees, compared to a 90% conviction rate against other taxpayers. It is also thought curious that no figures involving personnel corruption are available past 1936. The General Accounting Office, or GAO, recently tried to review allegations of IRS employee misconduct and found that it could not because of poor record keeping. A journalist reviewing the secret historical file found an IRS obsession with secrecy:
The IRS is very selective. Some cases are pending, others may deal with a confidential source or be considered an invasion of privacy, says Thomas Marusin, the IRS director of freedom of information. In places the report boasts that IRS goes after anyone who hasn’t paid taxes, no matter what their standing or influence, but then cases involving such people are blacked out. For example, the IRS boasts it has investigated numerous movie stars, but redacts every such name mentioned in the report. Several high-profile cases are discussed, including that of Vice President Spiro Agnew, who pleaded no contest to one count of evading $13,551 of federal income taxes after having “extorted bribes for almost a decade,” according to the IRS file.
The journalist also notes that much of the file praises the Criminal Investigations Unit, offering numerous statistics on conviction rates and detailing investigative techniques, such as sending undercover tax agents to infiltrate mobs and gambler trains.
In 1997, Charles Rossotti was confirmed as commissioner of the IRS and promised a new agency that would emphasize service and uphold taxpayer rights. This assertion was in response to concerns raised by the aforementioned congressional hearings and horror stories in the press. Rossotti emphasized how he would reform the IRS with private-sector principles of customer service. However, by 2002 he had gone so far as to bring back the old IRS practice of subjecting thousands of innocent taxpayers to audits for “research” purposes, one of the practices that brought about the congressional hearings in the first place. Civil libertarians expressed concerns about the so-called National Research Program, which would conduct 50,000 random audits of individual taxpayers to build a database to better target audits. Critics call such investigations call them invasive and grueling for taxpayers and also note that they do not yield nearly as much useful information as promised. The last year such audits were performed under the old Taxpayer Compliance Measurement Program (TCMP) was 1988, and at the time, 54,000 taxpayers were subjected to exhaustive “line-by-line” audits in which they had to prove each item in their tax returns was accurate: “These often were called ‘audits from hell,’ and the IRS frequently required those subjected to them to produce highly personal documents, including marriage papers and birth certificates for their children.”
The IRS wanted to expand this program in 1995 to audit some 153,000 citizens and businesses, but Congress stopped this, comparing the audits to the Spanish Inquisition.
More recently, though, the IRS sees a different atmosphere on Capitol Hill and is taking advantage of it with a “strategic plan” for the agency’s Criminal Investigation Division to focus its energies away from illegal activity such as drug dealing and money laundering, and toward prosecuting “legal income cases.”
While Congress may want the IRS to focus on tracing money used by terrorists, one critic notes that it is more likely that the IRS will investigate the average citizen, stating, “The IRS likes easy targets. it’s the bully mentality. They don’t want to go after anyone who can fight back, so they go after people who won’t put up a fight.”
In 2005, the IRS Criminal Investigation Division (CID) initiated 4,269 investigations for: tax fraud, insurance fraud, excise tax fraud, gaming, abusive return preparers, corporate fraud, money laundering schemes, and narcotics enforcement, and 67% of those investigations resulted in a recommendation for prosecution, with 50% of those recommended prosecutions resulting in criminal convictions.
The statutes covering the activities of the IRS include those in the I.R.C., and crimes under this set of laws have a three-year statute of limitations, with certain exceptions that extend the limitations period to six years. The five I.R.C. sections falling under these exceptions are found in sections 7201, 7202, 7203, 7206, and 7212 (a). The statute of limitations in any case begins to run on the date the taxpayer files the fraudulent document or on the date of the last affirmative act of evasion, and the government needs to file a complaint within the limitations period in order to satisfy the statute of limitations, the government need only file a complaint within the limitations period.
The statute of limitations can be held in abeyance for tax evasion purposes if the accused is a fugitive, is outside the United States, or is involved in related enforcement proceedings. This would prevent a defendant from raising procedural issues to delay a tax violation so as to proceed beyond the statute of limitations period. Felony tax evasion is described in I.R.C. Section 7201, which has been called the “capstone of [this] system of sanctions.” In order to prove a violation under section 7201, the government must show first the existence of: a tax deficiency, that there was an affirmative act constituting an evasion or attempted evasion of the tax, and so willfulness. In this process, the government bears the burden of proving each element beyond a reasonable doubt. The existence of a tax deficiency is not clear-cut as courts disagree about what constitutes a tax deficiency, and this is viewed differently by different courts. Most circuits demand only a deficiency, except that the Second and Tenth Circuits require a “substantial” deficiency, referring to the “amount of the tax evaded,” not the amount of unreported income. The fact of a deficiency can be demonstrated by the use of either direct or circumstantial evidence, with the most accurate means of proving a deficiency by direct evidence being the “specific item method,” by which the taxpayer’s books and records provide direct evidence that the taxpayer did not report taxable transactions. Without such direct evidence, the government relies more on three methods to obtain circumstantial evidence of unreported taxable income: (i) net worth; (ii) cash expenditures; and (iii) bank deposits. The need to prove that there is a deficiency doe not require the government to prove “the extent of the deficiency with mathematical certainty” nor to prove the exact source of the unreported income. Instead, “The government may choose to proceed under any single theory of proof or a combination of circumstantial and direct proofs.”
Under Sec. 1.446-l (a)(4), all taxpayers must maintain accounting records to ensure that a correct tax return can be filed, and this requirement is supported by Regs. Sec. 1.6001-1 (a), which provides in part that “any person subject to [income] tax… shall keep such permanent books of account or records, including inventories, as are sufficient to establish the amount of gross income, deductions, credits, or other matters….” A challenge to the adequacy of books and records may arise during a tax audit. To settle such issues, the IRS prefers to use direct methods, considered the best method of proof. If direct methods or data are not available, the IRS may use indirect income reconstruction, unless the courts have already accepted the taxpayer’s books and records as reliable. Such indirect methods are ordinarily employed during investigations of civil fraud and criminal tax evasion when books and/or records are not available or are nonexistent. When the issue of possible civil and criminal sanctions is raised during an audit, the IRS may used indirect methods along with direct evidence from information returns or third parties’ records to establish the existence of underreported income.
The government most often uses the “net worth” method of proof to show tax evasion, and the CID must therefore establish the taxpayer’s opening net worth with “reasonable certainty” but does not have to establish with reasonable certainty the net worth for the subsequent years under investigation. Given that this method relies on circumstantial evidence alone, the court must ensure that the government meets its burden of proof beyond a reasonable doubt. A variant of this method is called the “cash expenditures” method by which the government seeks to demonstrate that the taxpayer’s expenditures taken from taxable income exceed the income reported by the taxpayer, meaning the taxpayer is spending more than he or she makes. The government does not try to allocate this to an exact source of unreported income as the government only needs to establish a “likely source” of unreported income or negate “reasonably possible nontaxable sources of income.” This method does not require the government to prepare a formal net worth statement, similar to that used under the “net worth method.” A related approach is the “bank deposits” method by which the government conducts a full investigation of the taxpayer’s bank accounts and compares taxable deposits with reported income. In this approach, a jury may infer tax evasion based on the difference between the two amounts. The researchers note,
An unchallenged IRS assessment of taxes serves as prima facie evidence of a tax deficiency when a taxpayer who files no return is charged with tax evasion. If a taxpayer does not file a return at all and refuses to give relevant information to the IRS, the IRS is authorized by the I.R.C. To create and execute a substitute return which may then serve as prima facie evidence of a deficiency.
Along these lines, the Eighth Circuit has held that, when a defendant does not “timely challenge the assessed deficiencies, they [become] administratively final,” and that “a formal tax assessment that has become administratively final is prima facie evidence of the asserted tax deficiency, and if unchallenged, it may suffice to prove this element of the crime.”
The court emphasized, however, that the IRS assessment only serves as prima facie evidence of a deficiency and “may be challenged by the defendant accused of tax evasion.”
There is an affirmative action requirement that the taxpayer provide the necessary information to the government for tax purposes and that taxpayer not lie. Sections 287 and 1001 of Title 18 of the United States Code make it a crime to 1) knowingly make a false claim upon or against the United States or to any department or agency thereof and to 2) knowingly and willfully make a false statement to the United States or to any department or agency thereof, respectively. Statute 31 U.S.C. [subsection] 3729-33 addresses the civil prosecution of false claims. These three statutes were covered by just one statute from 1863 to 1948, and they contain very similar elements. This fact gives prosecutors the ability to choose the statute under which to prosecute cases of fraud, and it also may not constitute a violation of the Double Jeopardy Clause to punish defendants under both [section] 287 and [section] 1001 because the language of the statutes shows that Congress intended to create two distinct violations. There are some significant differences among the three statutes just the same:
For example, while materiality is an element of [section] 1001 regardless of which portion of [section] 1001 is at issue, the circuits are split on whether materiality is an element of [section] 287.8 in addition, [section] 1001 requires that the prosecutor prove the defendant both knowingly and willfully lied to the government. However, the circuits are divided on the intent requirement for [section] 287.
For a conviction, the government must prove five elements of the crime: (i) the defendant made a statement or concealment; (ii) the statement was false; (iii) the statement or concealment was material; (iv) the statement or concealment was made “knowingly and willfully”; and (v) the statement or concealment falls within executive, legislative, or judicial branch jurisdiction.
More and more of what the CID investigates comes under the heading of computer crimes, necessitating a high degree of expertise on the part of investigators in order to find the information needed and care in the development of evidence so it can be offered in court. Indeed, the IRS-CID was among the first government agencies to have an overt and public requirement to carry out forensics on external systems. In the beginning, the only forensic methods available to preserve evidence were to back up films from the evidence disk to magnetic tape to preserve file attributes and then to restore these files to another disk so they could be examined using command line and file management software. By the late 1980s, the method was now logical backup, copying the file and directory structure of a disk to the backup media allowing for a selective backup and restoration of files to the system. However, this approach left much to be desired as it did not duplicate free space and so was incomplete as evidence. Other methods were used that left the government open to charges of possible alteration of data in the process used. The need for specific forensic applications led to the creation of software just for this purpose. The other problem was a lack of training for those doing the investigation, and the CID has addressed this with extensive training programs for its analysts.
A continuing problem faced by the CID is a lack of resources, and this has mad more aggressive pursuit of cases virtually impossible. The IRS is simply not prepared to handle the heavier workload that would if the number of cases were increased substantially. This was shown recently by an audit of the IRS Questionable Refund Program by the Treasury inspector general. A shortage of resources has been shown to threaten the agency’s ability to pursue low-value cases of tax cheating even when they are relatively simple. The program was reviewed before the 2006 filing season to address concerns over a backlog of cases in which taxpayers were not notified when their refund was frozen, often not notified for several years, because of fraud concerns. Changes in procedure were instiuted to limit the duration of the freezes, but the report note that this change resulted in the issuing of nearly $15.9 million in potentially fraudulent refunds.
James L. Craig, Jr. Notes that the IRS is now using a new auditing approach called financial status auditing in order to increase the effectiveness of the effort of uncovering unreported income. The intent is for the IRS agent to determine if the income reported on the tax return matches with the financial status of the taxpayer, and the agents are trained to gather the financial status information by directly interviewing the taxpayer. Such training prepares the agent to begin probing for unreported income at the very beginning of the examination and then to follow up on leads so ascertained. Certain assumptions are often used in making these investigations, and this leads to some concern about the way the investigation is conducted: “There is no question that an appropriate role of the IRS is to monitor and see that the system is working. Yet, there is a serious question as to the appropriateness of the IRS carrying out that role on the assumption that taxpayers are intentionally underreporting income on their tax returns.”
The investigative arm of the Internal Revenue Service is the Criminal Investigation Division (CID), the unit within the agency that investigates suspected tax avoidance and fraud following the guidelines set forth in the statutes and using methods developed over the years in order to prove to a court that a crime has been committed. An agent is put in charge of a given case and must make a determination as to whether a crime has been committed, and he or she then reports to the proper agency, which uses the evidence developed by the CID for any prosecution that may take place. The IRS differentiates between civil recovery and criminal liability and uses the CID for the latter. The amount recovered in this manner is always far less than could be recovered if the agency had more resources and could seek more widely for evidence of fraud. The law changes from time to time, and the emphasis the IRS places on certain types of audit and certain types of crime also change from tie to time. The resulting uncertainty may contribute to an increase in tax avoidance from people who believe that the system is too overloaded to address their case. As noted, the IRS does tend to seek out high-profile cases and defendants first, using these as a deterrent to others, though the effect might be quite different if the public recognizes that this is how the IRS approaches these issues. At the same time, increasing the number of investigations might not be possible under the fiscal constraints placed on the agency. It might be possible to increase the reach of the investigators with some form of computer program to find mismatches between income and expenditures on a wide scale, but this might be technically difficult or might run afoul of legal restrictions. The IRS might consider this sort of approach for the future.
Baker, Jeremy and Rebecca Young. “False Statements and False Claims.” American Criminal Law Review, Volume 42, Issue 2 (2005), 427.
Berlau, John. “Return of the ‘Audits from Hell’: IRS Commissioner Charles Rossotti Once Pledged to Champion Taxpayer Rights, but Instead Americans Find Themselves Facing the Resurrection of Random Audits.” Insight on the News, Volume 18, Issue 27 (July 29, 2002), 15.
Cochran, Amanda a. “Evidence Handed to the IRS Criminal Division on a ‘Civil’ Platter: Constitutional Infringements on Taxpayers.” Journal of Criminal Law and Criminology, Volume 91, Issue 3 (2001), 699.
Craig Jr., James L. “Guidance on Financial Status Audits: It’s Not Just for CPAs.” The CPA Journal (2007), http://www.nysscpa.org/cpajournal/1996/0796/features/Guida.htm.
Criminal Investigation Division.” Avantri Law (2007). http://www.taxdefendant.com/newsite/tax%20education%20articles/criminalinvestigationdivision.htm.
Gardner, John C. “Indirect Methods of Income Reconstruction.” The Tax Adviser (August 1, 1992), http://www.allbusiness.com/accounting-reporting/corporate-taxes-tax-audit/316780-1.html.
Gomez, David and Keith Schomig. “Tax Violations.” American Criminal Law Review, Volume 44, Issue 2 (2007), 1025.
Internal Revenue Service Criminal Investigations,” KarpHuerlinWeiss (2006), http://irs-investigations.com/.
Maier, Timothy a. “A Secret History of IRS Tax Cops.” Insight on the News, Volume 15, Issue 37 (October 4, 1999), 14.
Mandel, Jerry. “IRS Cites Lack of Resources to Review Potential Fraud Cases.” Government Executive.com (June 13, 2007), http://www.govexec.com/dailyfed/0607/061307m1.htm.
McKenzie, Robert E. “IRS Criminal Investigation” (2006), http://www.mckenzielaw.com/CID.htm.
Mohay, George. Computer and Intrusion Forensics (Norwood, Maryland: Artech House, 2003.
Priester, Rachael Lebejko and Michelle J. Correll. “Tax Violations,” American Criminal Law Review, Volume 39, Issue 2 (2002), 1103.
Amanda a. Cochran, “Evidence Handed to the IRS Criminal Division on a ‘Civil’ Platter: Constitutional Infringements on Taxpayers,” Journal of Criminal Law and Criminology, Volume 91, Issue 3 (2001), 699.
Rachael Lebejko Priester and Michelle J. Correll, “Tax Violations,” American Criminal Law Review, Volume 39, Issue 2 (2002), 1103.
Robert E. McKenzie, “IRS Criminal Investigation,” 2006, http://www.mckenzielaw.com/CID.htm.
Ibid., Section 2.20.
Ibid., Sections 2.30-2.40.
Ibid., Section 2.40.
Ibid., Section 2.60.
Criminal Investigation Division,” Avantri Law (2007), http://www.taxdefendant.com/newsite/tax%20education%20articles/criminalinvestigationdivision.htm.
Timothy a. Maier, “A Secret History of IRS Tax Cops,” Insight on the News, Volume 15, Issue 37 (October 4, 1999), 14.
John Berlau, “Return of the ‘Audits from Hell’: IRS Commissioner Charles Rossotti Once Pledged to Champion Taxpayer Rights, but Instead Americans Find Themselves Facing the Resurrection of Random Audits,” Insight on the News, Volume 18, Issue 27 (July 29, 2002), 15.
Internal Revenue Service Criminal Investigations,” KarpHuerlinWeiss (2006), http://irs-investigations.com/.
David Gomez and Keith Schomig, “Tax Violations,” American Criminal Law Review, Volume 44, Issue 2 (2007), 1025.
John C. Gardner, “Indirect Methods of Income Reconstruction,” the Tax Adviser (August 1, 1992), http://www.allbusiness.com/accounting-reporting/corporate-taxes-tax-audit/316780-1.html.
Jeremy Baker and Rebecca Young, “False Statements and False Claims,” American Criminal Law Review, Volume 42, Issue 2 (2005), 427.
George Mohay, Computer and Intrusion Forensics (Norwood, Maryland: Artech House, 2003), 113-116.
Jerry Mandel, “IRS Cites Lack of Resources to Review Potential Fraud Cases,” Government Executive.com (June 13, 2007), http://www.govexec.com/dailyfed/0607/061307m1.htm.
James L. Craig Jr., “Guidance on Financial Status Audits: It’s Not Just for CPAs,” the CPA Journal (2007), http://www.nysscpa.org/cpajournal/1996/0796/features/Guida.htm.
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- When assigning your order, we match the paper’s discipline with the writer’s field/specialization. Since all our writers are graduates, we match the paper’s subject with the field the writer studied. For instance, if it’s a nursing paper, only a nursing graduate and writer will handle it. Furthermore, all our writers have academic writing experience and top-notch research skills.
- We have a quality assurance that reviews the paper before it gets to you. As such, we ensure that you get a paper that meets the required standard and will most definitely make the grade.
In the event that you don’t like your paper:
- The writer will revise the paper up to your pleasing. You have unlimited revisions. You simply need to highlight what specifically you don’t like about the paper, and the writer will make the amendments. The paper will be revised until you are satisfied. Revisions are free of charge
- We will have a different writer write the paper from scratch.
- Last resort, if the above does not work, we will refund your money.
Will the professor find out I didn’t write the paper myself?
Not at all. All papers are written from scratch. There is no way your tutor or instructor will realize that you did not write the paper yourself. In fact, we recommend using our assignment help services for consistent results.
What if the paper is plagiarized?
We check all papers for plagiarism before we submit them. We use powerful plagiarism checking software such as SafeAssign, LopesWrite, and Turnitin. We also upload the plagiarism report so that you can review it. We understand that plagiarism is academic suicide. We would not take the risk of submitting plagiarized work and jeopardize your academic journey. Furthermore, we do not sell or use prewritten papers, and each paper is written from scratch.
When will I get my paper?
You determine when you get the paper by setting the deadline when placing the order. All papers are delivered within the deadline. We are well aware that we operate in a time-sensitive industry. As such, we have laid out strategies to ensure that the client receives the paper on time and they never miss the deadline. We understand that papers that are submitted late have some points deducted. We do not want you to miss any points due to late submission. We work on beating deadlines by huge margins in order to ensure that you have ample time to review the paper before you submit it.
Will anyone find out that I used your services?
We have a privacy and confidentiality policy that guides our work. We NEVER share any customer information with third parties. Noone will ever know that you used our assignment help services. It’s only between you and us. We are bound by our policies to protect the customer’s identity and information. All your information, such as your names, phone number, email, order information, and so on, are protected. We have robust security systems that ensure that your data is protected. Hacking our systems is close to impossible, and it has never happened.
How our Assignment Help Service Works
1. Place an order
You fill all the paper instructions in the order form. Make sure you include all the helpful materials so that our academic writers can deliver the perfect paper. It will also help to eliminate unnecessary revisions.
2. Pay for the order
Proceed to pay for the paper so that it can be assigned to one of our expert academic writers. The paper subject is matched with the writer’s area of specialization.
3. Track the progress
You communicate with the writer and know about the progress of the paper. The client can ask the writer for drafts of the paper. The client can upload extra material and include additional instructions from the lecturer. Receive a paper.
4. Download the paper
The paper is sent to your email and uploaded to your personal account. You also get a plagiarism report attached to your paper.
PLACE THIS ORDER OR A SIMILAR ORDER WITH US TODAY AND GET A PERFECT SCORE!!!