Members Only Study Group: IRS Criminal Investigations

Sep 06, 2012 3:00pm -
Sep 06, 2012 4:00pm

Event Description

This study group will discus how a taxpayer's case traverses a criminal investigation including such topics as eggshell audits; the various types of privileges and supporting case law; distinguish between indicators of fraud and affirmative acts of fraud; how, and what causes, a taxpayer's case is referred to Criminal Investigations, along with signs that a referral is likely; explain the procedures and possible avenues within the criminal investigation process; and the most frequently charged tax crimes.

Caroline D. Ciraolo
Partner, Rosenberg Martin Greenberg, LLP

Caroline D. Ciraolo defends individuals and businesses in federal and state civil tax controversies, civil tax litigation, and criminal tax investigations and prosecutions. She is a Fellow of the American College of Tax Counsel, a member of the CJA Panel for the U.S. Court of Appeals for the 4th Penalties Committee, and former Chair of the Tax Section of the Maryland State BarAssociation.

Recent publications include Frequently Charged Tax Crimes (2011); Effectively Representing Your Client Before the IRS (Chapter 8, ABA Section of Taxation, 2011); and The Morning After - What You Need to Know FBAR and International Information Returns Including Defending Against and Litigating the Penalties," CCH's Journal of Tax Practice & Procedure (October - November 2009).

Caroline is a 2010 recipient of the ABA Janet R. Spragens Pro Bono Award, member of the Advisory Board, CCH Journal of Tax Practice & Procedure, listed in Chambers USA (Nationwide - Tax Fraud), named in Maryland SuperLawyers (2009-2012), Top 25 (2010,2011) and Top 50 (2012) Women Attorneys in MD, and Top 50 (2011) and Top 100 (2012) Attorneys in Maryland, and recipient of the Best Lawyers in America, 2012 Lawyer of the Year - Litigation and Controversy - Tax (Baltimore, Maryland).


The College of New Jersey, B.S. in Finance (Honors) (cum laude) (1990)

University of Maryland, School of Law, J.D. (Honors) (1993)
University of Baltimore School of Law, LL.M. in Taxation (1994)

Brian J. Crepeau

Partner, Rosenberg Martin Greenberg, LLP
Brian J. Crepeau concentrates on federal and state tax controversy and litigation matters for individual and corporate taxpayers. He represents clients in all phases of administrative disputes before the Internal Revenue Service and Comptroller of Maryland, and litigates tax cases before the United States Tax Court.

Mr. Crepeau represents corporations in complex audits, and provides tax planning advice on a wide range of issues. His controversy and litigation expertise and experience extends to all areas of federal income taxation as well as state and local tax matters. As Certified Public Accountant and a Certified Fraud Examiner he is particularly skilled in cases involving accounting practice and procedures and fraud.

Before graduating from law school, Mr. Crepeau worked for a regional public accounting firm, PG&E Corporation and a global consulting firm. In this capacity he has advised private and public companies across multiple industries on SEC and financial reporting, taxation matters and Sarbanes-Oxley issues.

Prior to joining the firm in 2008, Mr. Crepeau practiced in Annapolis, Maryland and acted as a consultant to international law firm's on accounting fraud, SEC investigations, revenue recognition issues, fraudulent business mergers and acquisitions, and tax fraud and evasion.

Practice Areas:

Federal and State Tax Controversies and Litigation
Criminal Tax Defense
Business and Transactional Matters
Estates and Trusts


Maryland State Bar Association
Anne Arundel Bar Association
American Associate of Attorney-Certified Public Accountants
American Institute of Certified Public Accountants
Maryland Association of Certified Public Accountants
Association of Certified Fraud Examiners

Bar Admissions:

U.S. Tax Court


Bridgewater State University, B.S. in Management Science-Accounting (1997)
American University, Washington College of Law, J.D. (2003)


2011-2012 FIVE STAR Wealth Manager Award Winner
Martindale-Hubbell® Peer Review Rated - AV® Preeminent™
Maryland Super Lawyers Rising Star (2012) - Tax

Event Type:Study Group
Category:Study Group
Early registration ends on Aug 09, 2012.
Regular registration starts on Aug 10, 2012 and ends on Sep 04, 2012.
Late registration starts on Sep 05, 2012.
(GMT-05:00) Eastern Time (US & Canada)