The Special Agent's Report (aka pros report) is a compilation of all the information that the government believes is relevant for a criminal tax prosecution.  It should be in the discovery file.  The PDF file is easy to navigate, but the instructions are at the very end of the file. Although the report is around 30 pages, the full PDF file will be hundreds or thousands of pages long, because every allegation is corroborated by evidence in the report.  A thorough review of the report is necessary to understand the government's evidence.

www.robertnordlander.com
www.nordlandercpa.com
Criminal Tax Secrets: What Every Defense Attorney Should Know

Large differences exist between a civil tax investigation and a criminal tax investigation.  Knowing these differences is important in defending taxpayers in a criminal tax investigation.  Just because someone worked for the IRS doesn't make them the best choice in assisting in criminal tax matters.  In this episode, I explain the differences and why it matters.

Badges of fraud are taxpayer behaviors that the civil side of IRS is trained to look for during their assessment and collection activities.  In this episode, I review common examples of the badges of fraud the lead to a fraud referral for a criminal tax investigation.

www.nordlandercpa.com