The IRS has launched a major offensive against what it terms “abusive tax shelters.” These are typically shelters in which the IRS believes there to be no legitimate purpose but the evasion of taxes. Many such shelters involve the use of “family” trusts and other garantor trusts and other trust mechanisms. Many criminal investigations into abusive tax shelters target the promoters of the shelters, and not the taxpayer. Recently, however, the IRS has made it a point of emphasis to target individual taxpayers who fall within certain prosecution guidelines.
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