During this session we will define and discuss Trust Fund Recovery Penalties along with identifying what IRS Criminal Investigation investigative priorities are and how you can assist your clients in both situations.

Who May Be Assessed Trust Fund Recovery Penalties (TFRP)?

• Define Trust Fund Taxes;

• Who is a Responsible Person?;

• What are the Willfulness Factors?; and

• Preparing a Reasonable Cause Statement.

Introduction to IRS Criminal Investigation

• What are IRS CI Priorities in Fiscal Year 2023

• Describe when a civil tax case potentially rises to a criminal tax investigation;

• Understand the role of a non-attorney practitioner in a criminal tax investigation; and

• Identify when to refer a client to an attorney.