LF logo
by learnformula
search
Log in
search
Courses/Law/Tax Law

The Anatomy of a Civil Tax Controversy Part 4

Master the intricacies of civil tax controversies, from navigating IRS examinations to understanding the delicate balance between civil and potential criminal tax issues.

Created byMichael J. DeBlis III, Esq.
BeginnerUpdated Sep 17, 2025
The Anatomy of a Civil Tax Controversy Part 4

What You'll Learn

check_circleAnalyze civil tax controversy progression.
check_circleUnderstand tax court and federal court paths.
check_circleIdentify criminal potential in tax cases.
check_circleGrasp tax practitioner-client privilege limits.
check_circleRecognize IRS appeals’ dispute resolution role.
check_circleAssess hazards of tax litigation.

About This Course

Delve into the intricate world of civil tax controversies with "The Anatomy of a Civil Tax Controversy Part 4." This course offers an in-depth exploration of how tax disputes escalate from initial audit to potential criminal referral and the nuances of the IRS appeals process. Understading these dynamics is crucial for any legal or financial professional navigating the complexities of tax law.

Upon completion, you will be able to:

  • Identify the types of cases susceptible to criminal prosecution referral by the IRS Criminal Investigation (CI) unit.
  • Understand the concept of and warning signs associated with "eggshell audits" and their potential to turn civil cases criminal.
  • Grasp the critical role of the tax attorney in mitigating criminal exposure, particularly in cases involving undisclosed foreign bank accounts.
  • Differentiate between various professional privileges (tax practitioner-client vs. attorney-client) in the tax realm and their practical limitations.
  • Explain the function and independence of IRS Appeals, including its role as a mediator and the hazards of litigation considered during the appeals process.
  • Navigate the procedural requirements for requesting an appeal and the types of issues that can be raised by taxpayers.

This installment provides invaluable insights for effectively representing clients and safeguarding their interests amidst civil tax controversies, equipping you with the knowledge to strategically manage cases from civil examination to potential criminal implications and through the appeals process.

Your Instructor

Michael J. DeBlis III, Esq.
Michael J. DeBlis III, Esq.

Trial, entertainment law and U.S. international tax law

menu_book70 courses
star736 reviews

Michael is a partner in the boutique law firm of DeBlis Law where he specializes in tax compliance and entertainment law. Michael graduated from Western Michigan University School of Law in 2007 and later went on to earn his Masters of Law in taxation (LL.M.) from Thomas Jefferson School of Law in 2012. As a former public defender, Michael has spent nearly eight years cutting his teeth on some of the most serious felony cases to pass through the state courts of New Jersey. Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of federal taxation make him uniquely qualified to handle any white-collar case, no matter how sophisticated it might be. Michael is known for his creativity, his charismatic personality, and his unyielding dedication to his clients. As a graduate of the National Criminal Defense College, Michael has trained under some of the best known criminal defense attorneys in the country. That experience has taught him that justice for a person accused of a crime is only won through a full understanding of the client and the case. To that end, Michael attempts to understand each client’s case as a convincing narrative, not just as a set of innocuous facts and arcane legal rules. When he's not in the courtroom, you can find Michael on stage. As a professionally trained actor, Michael's passionate about helping trial lawyers harness the power of persuasion and positive communication in the courtroom in order to connect to the jury on a human level. Michael's training as an actor allows him to combine a unique blend of left-brain thinking with right brain artistry to make even the most dull and abstract areas of the law come to life. This burst of creativity has contributed to Michael's success as a distinguished author and sought-out speaker. Michael has written articles that have been published in leading tax journals, such as "CCH Journal of Tax Practice and Procedure," "EA Journal," "Global Tax Weekly," and "ABA News Quarterly" and is a columnist for "Law360." He has been featured on the media affiliates of several major media networks, including NBC, ABC, CBS, Fox, and CNN. Michael is a living example of the tremendous power that comes from combining passion, preparation, persuasion, and positive communication in the courtroom. His courage and relentless work ethic have earned him a reputation as a zealous advocate and one of New Jersey's rising stars of the legal profession.

Credit Information

What Students Are Saying

0.0
Student's Choice
0 reviews

Frequently Asked Questions

We are a registered provider with 327+ associations and regulatory bodies worldwide. We operate across 29 global markets including Canada, the US, Australia, and the UK. Every course page clearly displays its specific accreditations. Upon completion, you receive a professional certificate that can be validated online. Our certificates include all necessary accreditation details, credit hours, and completion dates, and are formatted specifically to meet the submission requirements of most global regulatory bodies.