Caroline D. Ciraolo moderated a panel titled "The New Wave Of Fraud Referrals – IRS Collections" at the 2018 ABA Taxation Section Midyear Meeting in San Diego, CA

Taxpayers with unpaid tax liabilities who take steps to minimize or conceal their income and assets are the subject of increased scrutiny by the Internal Revenue Service and the Department of Justice. IRS Field Collections and Criminal Investigation are working together to train revenue officers to identify fraudulent conduct and refer collection matters for criminal investigation, and the Tax Division has identified this area as a priority for criminal enforcement.

As a result, we are seeing an increase in fraud referrals involving evasion of payment, false statements, obstruction, and other violations based on false Collection Information Statements (Forms 433A and B), transfers of income streams and assets to family members and other nominees, the creation of new entities to avoid liens and levies, and other steps to evade IRS collection efforts. This panel discussed this enforcement initiative, the types of cases being referred, and best practices to avoid a fraud referral.