Civil or Criminal: Inside the IRS Office of Fraud Enforcement

Understanding how civil audits turn into criminal referrals is critical for any tax professional advising clients under IRS examination.

In this in-depth two-hour program, Tax Rep Network founder Eric Green is joined by Esther Robinson, a former member of the IRS Office of Fraud Enforcement, for a rare look inside how the IRS identifies, develops, and refers fraud cases to Criminal Investigation (CI).

The program begins with the foundational legal framework, including the landmark Tweel case and the ongoing risks associated with misleading taxpayers during civil examinations. Eric and Esther will review why the Office of Fraud Enforcement Office was created, and Esther will provide insider insight into her years as both an auditor and fraud enforcement officer about how the Office of Fraud Enforcement operates, and how it works behind the scenes to support revenue agents in building stronger fraud cases.

Attendees will gain a clear understanding of how auditors are trained to recognize fraud indicators, how fraud development differs from routine audits, and what makes a referral “CI-ready.” Just as importantly, the program will explore what tax professionals should be watching for when a case begins to shift from civil to criminal exposure—and how missteps by representatives can dramatically increase risk for both the client and the practitioner.

Learning Objectives

• The legal and ethical risks of the IRS misleading taxpayers during civil audits
• Why the IRS established the Office of Fraud Enforcement
• How auditors are trained to identify and develop potential fraud cases
• What the IRS looks for before referring a case to Criminal Investigation
• Practical warning signs that a civil case may be moving toward criminal exposure

This program is essential for EAs and CPAs who handle audits, examinations, or high-risk compliance matters and want a deeper understanding of how fraud cases are built—and how to protect their clients and their practices.

Eric Green – Attorney and Founder, Tax Rep Network

Attorney Eric L. Green is a practicing tax attorney, author, speaker, and coach. He founded Tax Rep LLC which runs the popular tax representation practice-growth training and coaching program Tax Rep Network. Through his role as the primary instructor and coach at Tax Rep Network, he has helped thousands of accountants start and grow successful tax representation practices.

Eric is a partner and founder of law firm Green & Sklarz LLP, which is based in New Haven, Connecticut, where his focus is taxpayer representation before the IRS, Department of Justice Tax Division and state departments of revenue. Prior to becoming an attorney, Eric served as a senior tax consultant for national and international accounting firms, including KPMG and Deloitte & Touche.

Eric developed a national reputation by building a remarkable record of negotiating favorable settlements in thousands of civil cases against government agencies and has also been able to convince government agents and attorneys to forgo criminal charges and civilly resolve many cases.

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Esther Robinson – CPA, Former IRS Fraud Enforcement Advisor

Esther Robinson is a Certified Public Accountant and former IRS Fraud Enforcement Advisor with over 15 years of experience in fraud enforcement, forensic accounting, tax controversy, and compliance. During her tenure with the Internal Revenue Service, Esther worked in the Office of Fraud Enforcement with multiple operating divisions, where she developed national fraud programs, trained examiners on identifying civil and criminal fraud, and advised executives, counsel, and enforcement agents on high-impact investigations.

As founder of Treestone Advisory, Esther works with accounting, tax, and legal professionals who need forensic insight or assistance in complex financial matters. She draws on her deep understanding of IRS procedures and investigative methods to support practitioners in resolving fraud and compliance issues with precision and integrity.

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Program Number: 15UFN-T-00xxx-26-O
Title: Civil or Criminal: Inside the IRS Office of Fraud Enforcement

Green & Sklarz, LLC is the sponsoring organization for Tax Rep LLC’s CPE programming. Green & Sklarz, LLC is registered with the National Association of the State Boards of Accountancy (NASBA) as a sponsor of continuing education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org. Green & Sklarz, LLC’s NASBA sponsor number is 132892.