With the increased focus on tax enforcement by the IRS and New York State and City tax departments, taxpayers and their accountants should be prepared for if and when their return is selected for audit. One type of civil audit that you should become familiar with is the eggshell and reverse eggshell audits. Both eggshell and reverse eggshell audits involve civil audits which may lead to criminal investigations. Both accountants and their clients face exposure in these matters, and both need to be aware of the tell-tale signs for when a civil audit is or will turn into a criminal investigation. This seminar will highlight the areas that the tax agencies are focusing on, the different strategies practitioners need to consider in handling these types of audits and best practices for protecting themselves and their clients.

Topics & Learning Objectives Include:

• How to prepare for an eggshell and/or reverse eggshell audit
• Common and uncommon defenses
• Responding to IDRs and Summons'
• Privilege vs confidentiality
• Strategies for avoiding criminal referrals