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3. Ronny Refundable is under investigation by CI personnel of the IRS. Ronny is an accountant who prepares approximately 1,500 returns a year. Of the returns that he prepares for individuals, 95% produce a refund. Ronny accomplishes this by utilizing pre-prepared schedules showing itemized deductions, employee business expenses, and child care credits. It is Ronny's boast that by a careful combination of his schedules he can produce a refund for virtually any taxpayer in any tax bracket, unless the taxpayer happens to be subject to the alternative minimum tax. While those of Ronny's clients who have been audited have not fared well, Ronny points out to potential clients that fewer than two percent of taxpayers nationwide get audited and so the odds are good that they won't get caught. You are the Special Agent in Charge for Ronny's office. Would you recommend prosecution in his case? What sections of the Internal Revenue Code or other statutes have been violated by Ronny in his fictitious deduction and credit scheme? 4. Assume that you are Adele Accurate, an accountant, and that one of your clients is under criminal investigation. In accordance with the guidelines provided by the ABA and AICPA, you refer the client to an attorney familiar with criminal tax matters. You have prepared the client's returns for the past three years. The attorney retains you to make an analysis of the income and expenses of the client. Assume that you prepare a report for the attorney which discloses an understatement of income in excess of $35,000 for each year. (A) Is your report protected within the attorney-client privilege? (B) What practical problems does your retention cause? 5. Priscilla Persistent, a revenue agent, is auditing C\&C Bar and Grill. The bar and grill is a business operated by the husband and wife team of Clyde and Cindy Social. The business has no other employees. Clyde and Cindy deposit their "receipts" into their personal joint checking account. For tax purposes, however, the business files a Form 1065Return of Partnership Income. (A) Priscilla Persistent issued a summons to the taxpayers requesting the books and records of the business. Can Clyde and Cindy invoke their Fifth Amendment privilege against self-incrimination? (B) Would your answer change if the business run by Clyde and Cindy had several locations, numerous employees and substantial assets, and the business maintained a bank account in the partnership name? (C) What rights, if any, would Clyde and Cindy have if Priscilla issued a summons to their bank for copies of their records? (D) Would your answer to (C) change if a "grand jury investigation" had been commenced