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Origin of a Criminal Tax Case
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10th Cir 2d Cir 5th Cir accountant or returns administrative admissions agency alleged attorney-client privilege cert charges Chief of CID civil client conduct constitute conviction Crim crime criminal investigation criminal tax investigation Criminal Tax Trials defendant defendant's defense counsel denied Department of Justice disclose discusses dismiss District Counsel documents element enforcement evidence fact Federal Rules Fifth Amendment Fourth Amendment fraud referral furnished government's grand jury grand jury investigation immunity income indictment or information infra Internal Revenue interrogation IRS agents IRS's issue legal duty letter rogatory ment method of proof Miranda warnings motion obtain person plea pretrial prior procedures prosecution prosecutor records request returns preparer revenue agent search warrant seek special agent statements statute of limitations subpoena Supp supra note target Tax Division tax liability tax offenses taxpayer's attorney testimony tion U.S. Tax Cas undercover United States Attorney violation voluntary disclosure