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Tax Controversies: Audits, Investigation, Trials (41st edition)

By: Robert S. Fink
41st Ed. 2022

The 41st edition of “Tax Controversies: Audits, Investigations, Trials” has been published and is available on Lexis-Nexis. Authored by Kostelanetz & Fink co-founder Robert S. Fink and the attorneys of Kostelanetz & Fink, Tax Controversies is the recognized guide to all stages of tax examination, investigation, litigation, and prosecution — civil or criminal — including coverage of:

  • Tax shelters, summons enforcement litigation, and developments in the area of attorney-client privilege invoked in ongoing tax shelter litigation
  • Corporate criminal tax issues and relevant provisions of the Sarbanes-Oxley Act
  • Corporate criminal liability and analysis of prosecutorial discretion and the role of the Department of Justice’s so-called, “McNulty, Filip and Yates Memoranda” in criminal investigations of corporations and their employees
  • New provisions in the Federal Rules of Evidence governing the inadvertent production of privileged materials
  • The Justice Department’s new policies for criminally investigating corporate conduct
  • New Justice Department guidelines governing the waiver of the attorney-client privilege during the course of corporate criminal investigations
  • New Freedom of Information Act (FOIA) amendments aimed at reversing the trend of excessive delays by agencies in response to a FOIA request
  • IRS investigative powers and taxpayer rights and protections
  • Defenses

Tax Controversies includes valuable source material, IRC and Criminal Code sections, Treasury regulations applicable to return preparers, Civil and Criminal Litigation forms, IRS forms, and Jury Charges.

The book can be found here.