The Fifth Amendment and The Conjurer’s Circle: Exploring the Privilege Against Self-Incrimination in Federal Tax Practice

Timothy M Todd

The Fifth Amendment and The Conjurer’s Circle: Exploring the Privilege Against Self-Incrimination in Federal Tax Practice

School of Law

Research output: Contribution to journal › Article › peer-review

Abstract

Federal tax practice is unique in that it comprises civil, criminal, and administrative law, and it is replete with self-incrimination concerns. This article discusses the application of the Fifth Amendment in the various stages of federal tax representation, including the return stage, the examination and audit stage (including eggshell audits), civil tax cases, and criminal tax cases.

Original language	American English
Journal	Charleston Law Review
Volume	9
State	Published - 2014

Disciplines

Criminal Law
Criminal Procedure
Tax Law

Cite this

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abstract = "Federal tax practice is unique in that it comprises civil, criminal, and administrative law, and it is replete with self-incrimination concerns. This article discusses the application of the Fifth Amendment in the various stages of federal tax representation, including the return stage, the examination and audit stage (including eggshell audits), civil tax cases, and criminal tax cases.",

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