Overview of Criminal and Civil IRS Tax Investigations

As we enter the 2026 filing season, the IRS has deployed advanced machine-learning algorithms to replace the manual review of tax returns. For taxpayers, this means a significantly higher "hit rate" for civil audits and a faster referral process to the Criminal Investigation (IRS-CI) division.

This webinar explores the critical distinction between a routine civil audit and the specialized, high-stakes nature of an IRS-CI probe. We will examine how the 2026 IRS workforce reduction has led to a reliance on "data-driven" enforcement and how the OBBB has introduced new "Badges of Fraud" that can trigger life-altering legal consequences.

Learning Objectives:

Differentiate between the Civil "Preponderance of Evidence" and the Criminal "Beyond a Reasonable Doubt" standards of proof.
Identify the specific 2026 "Badges of Fraud" that cause an IRS Civil Agent to suspend an audit and refer a case to IRS-CI.
Analyze the impact of the One Big Beautiful Bill (OBBB) on enforcement priorities, specifically regarding the new 100% "Qualified Production Property" (QPP) deductions.
Master the 2026 protocol for interacting with IRS Special Agents, including understanding when the "IRS Miranda Warning" is required.
Apply best practices for managing digital assets and cryptocurrency transactions to satisfy the 2.35 petabyte-strong data analytics tools used by IRS-CI today.

Session Highlights:

Civil vs. Criminal IRS Investigations
Tax Fraud Identified: IRS-CI identified approximately $4.5 billion in tax fraud in Fiscal Year 2025 (FY25).
The Increase: This amount is more than double the figure from the previous year (FY24).
Key differences in purpose, burden of proof, and outcomes
How civil cases can escalate into criminal matters
IRS Enforcement Structure

Roles of Revenue Agents, Revenue Officers, and CI Special Agents
How cases are referred within the IRS

Common Triggers for IRS Investigations

Underreported income
Offshore accounts and foreign asset reporting
Payroll tax noncompliance
Fraud indicators and whistleblower tips

Investigation Process & Timeline

Initial contact and information requests
Interviews, summonses, and evidence gathering
Case development and resolution paths

Taxpayer Rights and Representation

Right to representation
Fifth Amendment considerations
Managing communications with the IRS

Penalties and Consequences

Civil penalties and fraud penalties
Criminal charges and potential sentencing
Voluntary disclosure considerations

Best Practices for Tax Professionals

Risk assessment and early intervention
When to involve legal counsel
Protecting clients and mitigating exposure

Who Should Attend

CPAs and Enrolled Agents
Tax Attorneys and Legal Professionals
Compliance Officers
Financial Advisors
Business Owners and Executives
Anyone involved in IRS compliance or dispute resolution

Credits and Other information :

IRS CPE Credits: 2.0 TAX

Session Prerequisites and preparation: None

Session learning level: Basic

Location: Virtual/Online

Delivery method: Group Internet Based

IRS Course ID: DFFSC

Attendance Requirement: Yes

Session Duration: 120 Min

Case Studies and Live Q&A session with speaker

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