Nestled within the many criminal sanctions of the Internal Revenue Code is a little known, less understood, and, until recently, seldom used statute proscribing attempts to interfere with administration of the Internal Revenue laws. This article will discuss the exponential increase in use of that provision, section 7212(a) of the Internal Revenue Code, in the last decade to seek prosecution of tax scofflaws, particularly practitioners, who might have otherwise escaped criminal sanctions. This article will call attention to some perils for the practitioner relating to representing a client on tax matters. Those perils include possible criminal prosecution of an attorney for her advice to a client.
"Practitioners - Beware the Trojan Horse: The Government Unsheathes an Old Weapon to Target Practitioners for Criminal Tax Offenses,"
Akron Tax Journal: Vol. 13
, Article 3.
Available at: https://ideaexchange.uakron.edu/akrontaxjournal/vol13/iss1/3