During federal criminal court proceedings, IRS has the burden of proof. Should using the methods of proof outlined in the Internal Revenue Manual (IRM) be required for obtaining an acquittal during a criminal proceeding? Conversely, should IRS agents investigating tax crimes be required to follow the same methods of proof?
An IRS agent may criminally or civilly investigate a taxpayer for under-reporting income, overstating deductions or not reporting certain income. According to the Internal Revenue Manual (IRM), the IRS uses the methods of proof outlined in part nine of the IRM to evaluate the situation and proceed in a civil or criminal tax investigation case. An IRS agent has seven methods of proof made available by the IRM for guidance. They are:
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