Tax Crimes, now in it's Second Edition, covers both the substantive and procedural issues involved in the investigation, prosecution, and defense of criminal tax cases. The book begins with an overview of the criminal tax system and the personnel involved followed by the elements of the numerous crimes for which a defendant may be charged, focusing on key aspects such as willfulness. Next, the book covers how tax cases are investigated, including the most common steps from a civil tax examination through indictment. These chapters examine the tools the Government has at its disposal to obtain information, as well as the defenses a person under investigation may assert. The book then turns to trial and sentencing issues, including the ethical issues and collateral consequences that arise in the investigation and litigation of criminal tax cases.
Finally, the book provides a review of the criminal tax system, allowing the reader to put all the foregoing concepts together, with a special emphasis on practical tips for handling these complex and exciting cases. Each chapter closes with a practical problem designed to highlight some of the key issues addressed in the cases and materials. The problems are based on situations encountered in practice or found in decided cases and many of them require analysis of a given set of facts to first determine and then resolve the critical issues.