This course defines an eggshell audit and why an eggshell audit is extremely important when a potential client has criminal exposure. It reviews the various professional client privileges, including the Kovel Accountant, because it is important to understand how these privileges may impact an eggshell audit.
Knowing the facts that could trigger an eggshell audit is critical. This course informs attorneys on how to prepare for such a possibility, including what a trained IRS Revenue Agent may see that could cause a criminal investigation referral.
The course explains indicators that a revenue agent may be looking to refer a client’s case to criminal investigation. It also covers tips on how to respond to IRS inquiries and what to do when the IRS demands to directly interview the client or requests an extension of the statute of the limitations.
Besides learning how to represent a client when confronted with an eggshell audit, viewers will learn whether an immediate return amendment is in the best interest of the client when errors are uncovered. Just as important, attorneys will learn how to protect themselves from any professional harm while representing this type of client.
Mr. Rooney is a graduate of the George Washington University National Law Center with honors, has a Master's Degree in Taxation from Georgetown University Law Center, and is a former attorney with the IRS National Office in Washington, DC. Mr. Rooney also passed the CPA examination. He is an expert in relieving taxpayers from IRS problems. Besides his tax practice, Mr. Rooney has taught tax courses at George Washington University Business School, & the VPI School of Business. He also conducts lectures of tax matters for private & governmental agencies and professional groups. Mr. Rooney is licensed to practice law in Colorado, Virginia, Maryland and Washington, DC.
Mr. Rooney practices in the areas of criminal and civil tax law controversies, including representation in IRS criminal investigations, regular and eggshell examination audits, IRS collection enforcement, and the elimination of income tax debts through bankruptcy.
Rooney is one of the best instructors I have ever seen, anywhere. Succinct, topical, knowledgeable. Excellent.
This was a very good and practical presentation.
Interesting and informative.
very good speaker
Nice presentation. Great examples.
Very interesting from a seasoned attorney. It was more preventives advice than anything.