Imagine a situation in which a client under audit by the IRS omitted $100,000 in income.

• Examine the significant factors relative to the omission by the client that would result in a criminal investigation rather than a civil fraud proposal by the IRS.

• Based on the guidance in Circular 230, speculate as to which provision the CPA violated and the extent of any sanctions for CPA for not detecting the omission.

• Based on the guidance in Circular 230, speculate as to which provision the CPA violated and the extent of any sanctions for CPA for not detecting the omission that would result in a criminal investigation rather than a civil fraud proposal by the IRS.