Crying Wolf: The IRS's Tax Fraud Allegations

Publication: Tax Notes Federal, June 24, 2024

Government officials have repeatedly described conservation easement transactions and employee retention credit claims as rampant fraud. William Stone explains the difference between civil and criminal tax fraud, the high burden the IRS carries, and the traditional badges of fraud courts look for.

He then compares the rhetoric with the record, including late-asserted fraud penalties and enforcement data on ERC claims. He argues that labeling whole categories of taxpayers as fraudulent erodes the government's credibility and, ultimately, voluntary compliance.

Related services: IRS Penalty Defense · IRS Audits & Examinations

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