By Caroline Rule Criminal Litigation December 2016 Edition Frequently, defense counsel in criminal investigations and prosecutions – particularly in tax-related prosecutions, but also in many other complex matters – cannot provide effective assistance to his or her client without consulting a non-attorney expert or professional, such as an accountant. The Second
By Caroline Rule The CPA Journal October 2016 Edition Will the Fifth Circuit Clarify the IRS’s Burden of Proof? District courts and other authorities disagree on whether the IRS must prove willfulness by a preponderance of the evidence or by clear and convincing evidence when seeking a civil penalty for willful
By Caroline Rule BNA Tax Management Portfolio No. 623-3rd July 26, 2013 Tax Management Portfolio, IRS Procedures: Examinations and Appeals, No. 623-3rd, describes and discusses the law applicable to, and the policies and procedures followed by, the IRS in the examination of tax returns and administrative appeals of examination determinations. It
