Celesq® Programs

Celesq® Master Tax Series - How the IRS Reconstructs Income in Tax Fraud Cases

Program Number
Program Date
CLE Credits

In one of the climactic scenes from 1954’s On The Waterfront, Crime Commission prosecutors had to make their corruption case against union boss Johnny Friendly (a/k/a Michael Skelly) by convincing a reticent yet pure-hearted Terry Malloy to come forward and tell what he knew about corruption in the International Longshoremen’s Association, beginning with the murder of Joey Doyle, because an underling insisted that “we were robbed last night and can’t find no books.” 

If that same case came up in 21st Century tax court, Eva Marie Saint and Karl Malden could’ve stayed at home rather than serving as Marlon Brando’s cheering section, because government prosecutors could reconstruct the ILA’s income, based on the records retention requirements in Section 6500 et seq.

In this course, we will discuss the elements of the federal tax evasion statue and delve into the methods that the IRS uses to reconstruct income in tax fraud cases.

Available in States

  • California
  • Colorado
  • Florida
  • Georgia
  • New Jersey
  • New York
  • Texas Self Study

Program Categories

  • Banking & Finance Law
  • Criminal Law & Procedure
  • Criminal Law & White Collar
  • Federal Courts
  • Financial Services
  • Florida Eligible
  • Government Claims & Military Law
  • Internal Revenue Service
  • Master Tax Series
  • Taxation Law


  • Areas of Professional Practice : 2 Credit