Tax Crimes

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LexisNexis, 2008 - Tax evasion - 534 pages
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Contents

TABLE OF CONTENTS
Overview of the Procedural Aspects of the System
PLAN OF THE BOOK
CHAPTER 2A CRIMES UNDER THE INTERNAL REVENUE CODE
WILLFULNESS
TAX DUE AND OWING
EX POST FACTO SOLUTIONS TO TAX EVASION
CHAPTER 2B CRIMES UNDER THE INTERNAL REVENUE CODE
INVESTIGATION AND DEVELOPMENT OF CRIMINAL
ADMINISTRATIVE CASES
EGG SHELL AUDITS
GRAND JURY SUBPOENA
DISPOSITIVE MOTIONS AND MOTIONS TO SUPPRESS EVIDENCE
PROBLEM
TRIAL AND POS T TRIAL
ETHICAL ISSUES IN CRIMINAL TAX PRACTICE

SECTION 72062 AIDING AND ASSISTING FALSE RETURN
SECTION 7203 FAILURE TO FILE KEEP RECORDS SUPPLY
SECTION 7207 FRAUDULENT RETURNS STATEMENTS
RELATED CRIMES OUTSIDE THE INTERNAL
AIDING AND ABETTING
MONEY LAUNDERING
MAIL FRAUD AND WIRE FRAUD
MODES OF PROOF
GOVERNMENT EMPLOYEES AS WITNESSES
PRESUMPTIONS
INTRODUCTION
AFFIRMATIVE DEFENSES
PROBLEM
CLIENT CONFIDENTIALITY AND DEALINGS WITH GOVERNMENT
CASH FOR SERVICES
PROBLEM
CIVIL DISABILITIES ARISING FROM CONVICTION
CIVIL TAX CONSIDERATIONS
A FINAL CAUTION
Appendix B ADDITIONAL RESOURCES
TABLE OF CASES
TABLE OF STATUTES
TABLE OF SECONDARY AUTHORITIES
INDEX
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