Volume 24 Issue 2 -- March/April 2012
The civil fraud
tax penalty
has been described by some as a double headache because it is usually
preceded
by a criminal tax proceeding and then a separate civil fraud penalty
action.
The purpose of this newsletter is to discuss the civil fraud penalty in
general
terms and provide a few pointers concerning it. There are lengthy
treatises on
the civil fraud penalty, and this
newsletter is not designed to handle such a massive subject in great
detail.
The policy of the
U.S.
Department of Justice is to refer any criminal tax case involving,
usually,
jail time or monetary penalties to the IRS after the Department of
Justice has
concluded its case, particularly if the taxpayer is found guilty. As
often
happens, it is frequently advantageous to plead guilty to a lesser
criminal
offense than to risk going to trial and being found guilty of tax
evasion and
sentenced to five or six years in jail.
The civil fraud
penalty is
75% of the tax liability, plus interest. Often, the civil fraud penalty
plus
the interest will exceed the original tax liability. This is typically
true
because it takes so long for the criminal case to get through the court
system.
By the time the taxpayer serves his or her jail time, many years can
elapse
before the civil fraud case comes to trial.
While criminal
tax cases
have to be conducted in the U.S. District Court, civil tax fraud is
always
tried in the U.S. Tax Court. Assuming the criminal matter did not
result in
plea or conviction of tax evasion, but rather some lesser criminal
offense,
then it is possible to contest the civil fraud penalty in the Tax Court. Often, the only issue in
the Tax Court is the
question of fraudulent intent.
Unusual for the
IRS attorneys,
they have the burden of proving fraudulent intent, not just negligence
or
carelessness. Typically, the IRS will have the Criminal Investigation
Report,
and the same agents that assisted in the criminal matter work in
conjunction
with the IRS trial attorneys to prepare the civil fraud case.
If an individual
pleads
guilty to tax evasion under Internal Revenue Code
§ 7201, there is no defense to the civil
fraud penalty in the Tax Court. There are, however, various criminal
tax
violations which do not automatically render the civil fraud penalty
uncontestable. For example, pleading guilty to filing a false return
does not
automatically prevent the taxpayer from defending his or herself
against the
civil fraud penalty, although the only ground for defense may be lack
of
fraudulent intent.
Some government
personnel
believe that if any criminal plea was entered the civil fraud penalty
is an
automatic entry, but this is not true unless one pleads guilty to tax
evasion.
Nonetheless, negotiating a settlement of the civil fraud penalty can be
difficult.
Having
to make a
choice between pleading guilty to a lesser tax crime versus going to
trial and
risking a conviction for tax evasion and the resulting civil fraud
penalty is
daunting. Going to trial and losing almost always results in more jail
time
than the jail time flowing from a plea. The fact that a taxpayer who
has pled
guilty to or been found guilty of a tax crime then has to defend him or
herself
against the civil fraud penalty is a terrific burden.
While not much
discussed,
there is an informal yardstick by which the Justice Department decides
which
cases to prosecute. It
appears that,
regardless of culpability, the Criminal
Investigation Division will not audit criminal tax activity unless
there is a
least $70,000 to $80,000 in potential tax liability at stake. Stated differently “small
fish” are often not
prosecuted even though many of the badges of fraud are present.
If your client is
being
investigated by the Criminal Investigation Division of the IRS, it is
essential
that an attorney knowledgeable about criminal tax cases be retained
early. In
appropriate circumstances, it may be possible to negotiate a plea deal
rather
than go before a jury.
For the
government, one
benefit of a criminal tax prosecution is the inevitable news release
following
the sentencing touting the government’s successful prosecution. Civil
tax fraud
litigation does not result in such news releases even though the Tax
Court
decision is a public document.
If the IRS
decides to impose
the Civil Fraud Penalty, it must first issue a Notice of Deficiency
asserting
the penalty. The taxpayer then has a choice of conceding the penalty or
contesting it by filing a timely Tax Court petition.
For those still in jail, it is common to
default on the Notice of Deficiency. Many are so despondent or
impoverished
that they ignore the Notice, default, and then face a large tax bill
when
released.
While Tax
& Business
Professionals does not handle criminal cases directly, if your client
is
involved in a criminal or potential criminal matter, you may want to
contact us
for advice.
While designed to be accurate, this publication is not intended to constitute the rendering of legal, accounting, or other professional services or to serve as a substitute for such services.
Redistribution or other commercial use of the material contained in Tax & Business Insights is expressly prohibited without the written permission of Tax and Business Professionals, Inc.
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