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38.2.1.1
(08-11-2004)
Noncomplex Cases
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Noncomplex cases are those in which the tax liability or unreported
income is established by the specific items method of proof, the appropriate
amount of yearly additional tax for criminal purposes is met for each year,
and only minimal adjustments to Criminal Investigation’s recommended
computations are required.
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Noncomplex cases should be reviewed and evaluated within 45 days of
receipt. See CCDM 38.2.1.3.
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An invitation for a conference will be extended in accordance with CCDM
38.2.1.4.2. Normally, conferences should be scheduled and held within 20 days
of receipt of the case to meet the 45-day processing requirement. Delays or
extensions of the date of the conference for the convenience of the taxpayer
or taxpayer’s representative beyond 20 days should be permitted only
if the Criminal Tax attorney and the Special Agent in Charge (SAC) agree that
a conference is necessary and will not extend the case completion date beyond
the 45-day limit.
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After reviewing the special agent’s report and exhibits, the Criminal
Tax attorney prepares an evaluation memorandum for the SAC that discusses
the legal issues and evaluates the prosecution potential of the case.
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