A recent client IRS tax matter required that I research criminal tax felonies associated with unreported income.  In addition, I researched the ABA Model Rules of Professional Conduct (Rules 1.2, 1.6), Attorney-Client privilege, Evidentiary and Statute of Limitations issues.  The following is a summary of my legal research which I hope may be beneficial to you (and your clients).

1) Unreported Income: IRS Criminal and Civil Tax Issues

2) Unreported Income: IRS Civil Tax Fraud and Criminal Tax Evasion

3) Unreported Income: Fraudulent Failure to File Tax Returns

4) Unreported Income: Criminal Penalties: Tax Preparers

5) Unreported Income: Tax Preparer (CPA) Civil & Criminal Penalties (Summary)

6) Unreported Income: Attorney client Privilege (CPA’s): U.S. v. Kovel

7) Unreported Income: Aiding & Abetting Understatements
(Tax Preparer Penalties)

8) Unreported Income: Understatement of Tax Liability (Tax Preparer Penalties)

9) Unreported Income: Jeopardy Assessment

10) Unreported Income: Voluntary Disclosure