There is a significant difference between a civil and criminal tax proceeding. Generally, IRS civil investigations are conducted by Revenue Officers who perform audits and other investigations. Criminal investigations are conducted by Special Agents with the Criminal Investigation Division (CID) of the IRS. IRS-CID agents investigate tax evasion, tax fraud, wilful failure to file income tax returns, money laundering offenses and structuring.
It is important for individuals to retain tax professionals when they are subjected to a civil audit. Then, if a referral is made to the Criminal Investigation Division, or a CID agent requests to interview the person, they should retain an experienced federal criminal defense attorney before moving forward.
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