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Tax Controversies: Audits, Investigation, Trials

By: Robert S. Fink
39th Ed. 2020

The 39th 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.

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