Have a Question? Search the Tax Rep Vault
TAX REP VAULT Exclusive Area
- Tax Rep Vault Home
- Critical Tax Cases
- Top Tax Q&As
< All Topics
Print
What does Obstruction under 7212(a) cover?
PostedNovember 17, 2025
UpdatedNovember 17, 2025
ByKlemens Raab
Obstruction is charged under IRC 7212 which is when a taxpayer or tax professional attempts to intentionally interfere, obstruct or impede the IRS from carrying out its normal functions, like an exam, collection activities, etc.
-
Criminal Tax
- What is tax evasion under IRC 7201? What causes a case to become criminal?
- Does Tax Evasion also cover collection cases?
- What is an example of evasion of assessment?
- What is an example of evasion of payment?
- Who can be guilty of tax evasion?
- Can you be charged for helping someone else evade taxes?
- What are the elements of evasion of assessment?
- What counts as an "attempt" to evade tax?
- What are examples of affirmative acts?
- Is just not filing a return enough for tax evasion?
- Does lying to an IRS agent count as evasion?
- Does a tax deficiency have to be large to be criminal?
- What kinds of income are taxable even if not listed in the code?
- Does the IRS have to formally assess the tax before charging evasion?
- Does the government have to prove the exact amount of tax owed?
- Is a good-faith misunderstanding of the law a defense?
- Can a client have a defense if they believed that they were not required to pay tax?
- How do prosecutors prove "willfulness"?
- Where can tax evasion be prosecuted?
- What is the statute of limitations for tax evasion?
- How can tax professionals get into trouble criminally?
- What does Obstruction under 7212(a) cover?
- What is 7212(b)?
- Can the IRS Revenue Agent or Revenue Officer lie to a taxpayer to get them to share information?
- How can a tax professional work on a criminal tax case?
- Show all articles (10) Collapse Articles