Do any of you folks have current information about the minimum tax due standards (a/k/a LEM Standards or Prosecution Standards) IRS-CI applies as part of its decision to pursue (or not pursue) a Joint Civil/Criminal Investigation?
I have a Client whose errors for a few tax years, though possibly willful, do not result in a high yearly or combined Tax Due. Very close to the Line but I'm not sure exactly what the LEM (IRS Law Enforcement Manual) minimums are.
Not even sure if LEM prosecution standards are disclosed in the IRM or by the criminal investigators upon request.
Thanks in Advance.
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