Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the IRS and DOJ have been challenged to come up with new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. This panel provides an update on new developments and priorities across the IRS and DOJ.
This Self Study features the following sections:
IRS CRIMINAL INVESTIGATION DIVISION UPDATE
Identify key initiatives, priorities, and challenges for different sections of the IRS.
John D. (Don) Fort is the Chief, Criminal Investigation, headquartered in Washington, DC. He was appointed to the position in June 2017 and heads the Internal Revenue Service Division responsible for investigating criminal violations of the tax code and related financial crimes. Mr. Fort oversees a worldwide staff of nearly 3,300 CI employees, including approximately 2,200 special agents, who investigate crimes involving tax, money laundering, public corruption, cyber, ID theft, narcotics and terrorist financing.
In December 2017, Richard E. Zuckerman, was appointed the Department of Justice Tax Division’s Deputy Assistant Attorney General for Criminal Matters and the Division’s Principal Deputy Assistant Attorney General. As Principal Deputy Assistant Attorney General, he serves as the Head of the Tax Division. The Tax Division’s 350+ attorneys are charged with enforcing the nation’s tax laws and represent the United States in civil and criminal matters across the country.
Prior to his appointment, Mr. Zuckerman spent more than 30 years as a partner and practice group leader of the White Collar Crime and Government Investigations Group at Honigman Miller Schwartz and Cohn LLP in Detroit, Michigan. He also served for nine years as a partner with Raymond Rupp Weinberg Stone & Zuckerman in Detroit, Michigan. Mr. Zuckerman has taken advanced education in taxation from Wayne State University School of Law in Detroit, has taught as an Adjunct Professor of Tax Fraud at various Michigan law schools, and also served as an instructor for Senior Special Agents of the Detroit Division of the IRS. He began his legal career as a trial lawyer with the Justice Department’s Organized Crime and Racketeering Section in the Detroit Strike Force. Among the matters he tried or co- lead while with the Detroit Strike Force was the 7 month net worth income tax evasion trial of alleged Detroit Mafia chieftain Anthony Giacalone, and the investigation into the disappearance of Jimmy Hoffa.
Morvillo , Abramowitz , Grand , Iason & Silberberg , P.C.
Jeremy H. Temkin represents individuals and corporations in white collar criminal investigations. He handles a wide variety of criminal, regulatory, and civil matters in state and federal courts and before arbitration panels. His cases have involved allegations of tax fraud and securities fraud (including claims of insider trading and accounting violations), as well as violations of the antitrust laws and the Foreign Corrupt Practices Act (“FCPA”). Jeremy has tried high-profile tax and securities fraud cases, has conducted internal investigations for public corporations and committees of their Boards of Directors, has represented employees in corporate internal investigations, and has litigated civil forfeiture issues arising out of money laundering allegations. He has counseled clients on issues relating to offshore bank accounts and the Internal Revenue Service’s Voluntary Disclosure Program, and served as Independent Examiner for numerous banks participating in the Department of Justice’s Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks. Jeremy has also represented various employees of the New York Yankees in witness interviews during investigative inquiries and he represented Muhammad Ali in civil litigation to recover stolen memorabilia.
Dean Zerbe was Senior Counsel and Tax Counsel for the Chairman of the Senate Finance Committee, Senator Charles E. Grassley, 2001-2008. At the direction of Chairman Grassley, Dean was the counsel responsible for the modern IRS whistleblower law – signed into law in 2006 — which established the IRS Whistleblower Office and created an award program for tax whistleblowers. Dean “wrote the law” when it comes to the IRS whistleblower office and reward program. Dean represents a select number of tax whistleblowers – including the most successful whistleblower in the history of the U.S. – Bradley Birkenfeld. Mr. Birkenfeld was awarded $104 million dollars – 26% of the $400 million in taxes paid – based on Mr. Birkenfeld blowing the whistle to the IRS about tax fraud by UBS.
Lee D. Martin is the Director of the Internal Revenue Service (IRS) Whistleblower Office. In this role, he serves as a principal advisor to the Commissioner and top IRS officials on the execution of the Whistleblower Program.
Previously, Lee served as Deputy Director for the Office of Professional Responsibility where he oversaw the conduct of attorneys, Certified Public Accountants, enrolled agents, enrolled retirement plan agents, actuaries and appraisers who practice before the IRS under Treasury Circular 230. Prior to this, Lee was the Director of Enterprise Networks Operations, in the Information Technology (IT) organization. In this role, Lee was responsible for providing executive leadership over the operations and maintenance of the enterprise-wide network infrastructure, while working closely with IT executives to ensure delivery of a world-class network and high quality services. Before joining the IRS, Lee held management positions with AT&T as Assistant Vice President-Project Management; Vice President-Information Systems/Chief Technologist of SBC Interactive – SmartPages.com, an on-line Directory Service. Lee also has an extensive background in Billing and Collections with SBC where he played a key strategic role at TelCel in Mexico City and Cable Northwest in Preston, England.
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