%0 Book %E Toscher, Steven R %I Tax Management %D 2011 %C Arlington, VA %G English %B Tax management portfolios ; %T Tax crimes %U http://taxandaccounting.bna.com/btac/display/link_res.adp?lt=email&fname=tm_636&split=1 %X "... discusses the area of individual and corporate criminal tax liability. The Portfolio begins with an explanation of the criminal offenses under the Internal Revenue Code and related offenses under the Criminal Code in Title 18. The elements of each offense are described in detail. The Portfolio also explains the principles and elements of corporate criminal tax liability. An extensive discussion of the administrative process and the investigatory tools used by the government to uncover criminal violations is provided. The Portfolio analyzes the rights of the taxpayer during a criminal investigation including the Fifth and Sixth Amendments as well as the various evidentiary privileges. Finally, the Federal Sentencing Guidelines are explained in detail including the base offense levels for each offense under the Internal Revenue Code as well as the adjustments to the base offense levels."