Facing the Civil Fraud Penalty? Here’s What You Need to Know
According to the IRS Criminal Investigations 2023 Annual Report, fraudulent schemes cost the government about $5.5 billion.
January 07, 2025 at 12:21 PM
6 minute read
If you are under investigation for tax fraud by the Internal Revenue Service (IRS), you are likely feeling a mix of anxiety and uncertainty. The civil fraud penalty is one of the most severe consequences a taxpayer can face. However, the good news is that understanding the process and knowing your rights can go a long way in protecting you from costly mistakes and ensuring that you handle the situation properly. Here is a comprehensive breakdown of the civil fraud penalty, what it means for you and how to protect yourself.
|
What Is the Civil Fraud Penalty?
The civil fraud penalty is imposed when the IRS determines that you intentionally falsified your tax return in order to evade paying taxes. According to Section 6663 of the Internal Revenue Code, the penalty amounts to a staggering 75% of the taxes owed. To make matters worse, even if the IRS proves that only a portion of the underpayment is attributable to fraud, the 75% penalty applies to the entire underpayment, except to the extent the taxpayer can show by a preponderance of the evidence the portions of the underpayment that were not fraudulent. Thus, for example, a $100,000 underpayment attributed to fraud becomes a $175,000 liability, plus interest on the full tax and penalty deficiency.
NOT FOR REPRINT
© 2025 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllClients, Not Counsel, Have Most To Gain from Georgia Tax Court, Lawyer Predicts
6 minute readGeorgia Removed From Lawsuit Challenging Student Loan Forgiveness; Case Transferred to Missouri
Reality TV Star Julie Chrisley Resentenced to 7 Years in Bank Fraud, Tax-Evasion case
5 minute readOff-Limits? Judicial Authority Takes Center Stage in Dispute Over Municipal Utility Rates
8 minute readTrending Stories
- 1NJ Manufacturing Company Sues Insurer to Recoup PFAS Remediation Losses
- 2Critical Mass With Law.com’s Amanda Bronstad: In Mass Arb Fight, Judge Goes After Keller Postman, Jenner & Block. Could Boeing Be Sued Over South Korea Plane Crash?
- 3Legal Tech's Predictions for Data Privacy in 2025
- 4The Corporate Transparency Act Meets the Fifth Circuit
- 5Big Company Insiders See Technology-Related Disputes Teed Up for 2025
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250