NCJ Number
120578
Journal
American Criminal Law Review Volume: 26 Issue: 3 Dated: (Winter 1989) Pages: 1031-1041
Date Published
1989
Length
11 pages
Annotation
While violations of the United States tax code can be prosecuted under many criminal tax statutes, the major felony provision for tax fraud is Section 7201 of Title 26 of the United States Code, which is discussed in detail.
Abstract
The elements of a Section 7201 offense are discussed, along with defenses to the alleged offense, the investigative procedures of the Internal Revenue Service, and relevant case law. Strategies for taxpayers under criminal investigation are discussed, and it is pointed out that manpower shortages in the Internal Revenue Service have forced the government to shift its focus away from ordinary tax offenders and towards the investigation of professional criminals. The Internal Revenue Service's dual roles of tax enforcement and wider-ranging non-income tax enforcement are assessed. 76 footnotes.