Handling A Case With Potential Criminal Problems

Handling A Case With Potential Criminal Problems


Christine S. Speidel & Patrick W. Thomas



This chapter addresses issues facing taxpayers whose conduct has crossed the line from mere negligence or civil fraud into the realm of criminal conduct. With a “tax gap” of approximately $441 billion per year,the government relies on criminal tax prosecutions to “to protect the public interest in preserving the integrity of the nation’s tax system. Criminal tax prosecutions serve to punish the violator and promote respect for the tax laws." However, the line between civil and criminal tax cases is often blurry, and many cases that could be prosecuted criminally are resolved through civil tax proceedings. The purpose of this chapter is to educate general tax practitioners to make them conversant on the subject and to assist them in knowing when a civil tax case has criminal potential. It is not intended to teach a general tax practitioner how to represent someone in this area of the law.

Title of Book

Effectively Representing Your Client Before the IRS, 8th Edition



Publication Date


Document Type

Book Chapter


American Bar Association


Criminal Law | Tax Law

Handling A Case With Potential Criminal Problems

Catalog Record