New IRS Office of Fraud Enforcement: Defending Civil Fraud Cases and Enforcement Actions, Avoiding Penalties

Issues for Small Businesses and Self-Employed Taxpayers: Real Estate, Cash Intensive Businesses and Companies Utilizing Cryptocurrency, and More

This program has been cancelled

A live 90-minute premium CLE/CPE video webinar with interactive Q&A

Thursday, May 27, 2021 (in 14 days)

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

This CLE/CPE webinar will provide tax professionals and advisers guidance on defending civil fraud cases in light of the new IRS Office of Fraud Enforcement. The panel will discuss recent IRS enforcement actions for civil fraud claims, navigating the processes involved for civil fraud cases, new procedures of the IRS Office of Fraud Enforcement, penalties, abatements, and key strategies for tax professionals.


Recently, IRS announced the formation of a new Office of Fraud Enforcement within its Small Business/Self-Employed Division. As the IRS expands its operations and enforcement actions, tax professionals and advisers must be proactive in defending taxpayers investigated by the IRS for suspected federal tax evasion and tax fraud—both criminal and civil.

The IRS has increased its pursuit of tax fraud cases against small businesses, self-employed taxpayers and is also focusing on larger corporations. Some businesses, such as cash intensive companies, real estate businesses, those involved in utilizing cryptocurrencies, and companies that sell coronavirus-related products and services, are prime targets and have a higher risk of being subject to IRS enforcement actions.

As with other IRS audits and investigations, investigations conducted by this new division of the IRS can lead to civil or criminal penalties. IRS agents are instructed to suspend examinations if there are any indications of fraud and refer it to IRS Criminal Investigation. Tax attorneys must implement a proactive defense by taxpayers and tax professionals to avoid liability for additional taxes, interest, and penalties.

Listen as our panel discusses recent IRS enforcement actions for fraud claims, navigating the processes involved in tax evasion and fraud cases, new procedures of the IRS Office of Fraud Enforcement, and key tax professionals' strategies.



  1. IRS Office of Fraud Enforcement
  2. Fraud enforcement actions
  3. Tax audits and collection cases
  4. Penalties and criminal prosecutions
  5. Best practices for tax professionals


The panel will review these and other key issues:

  • Overview of new IRS Office of Fraud Enforcement and enforcement initiatives
  • Key considerations and issues for certain small businesses and self-employed taxpayers
  • Managing tax audits and collection cases
  • Avoiding or minimizing penalties
  • Techniques for tax professionals representing taxpayers in fraud actions


Toscher, Steven
Steven (Steve) Toscher

Managing Principal
Hochman Salkin Toscher Perez

Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions...  |  Read More

Davis, Evan
Evan J. Davis

Hochman Salkin Toscher Perez

Mr. Davis represents individuals and closely held entities in criminal tax investigations and prosecutions, foreign...  |  Read More

Kalinski, Jonathan
Jonathan Kalinski

Hochman Salkin Toscher Perez

Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including...  |  Read More