Please read the following fact pattern and respond to the question below. The fact pattern is identical for all for questions. Please limit your response to 1000 words.

Fact Pattern

Willy Wonka is under investigation by the IRS Criminal Investigations Division. He is the president of Golden Ticket Enterprises, an S-corporation. Beginning in 2017, Willy Wonka, created a Florida corporation, Oompa Loompa Marketing, Inc. Oompa Loompa sends Golden Ticket a monthly invoice for $10,000. Every month, Golden Ticket writes a check to pay the invoice from Oompa Loompa. Willy has his secretary deposit this check to Oompa Loompa in a bank account at Never Never Land Bank, located outside of the United States.

Golden Ticket files an 1120-S every year and deducts the payments to Oompa Loompa as a business expense.

Willy timely filed personal tax returns for 2018, 2019, and 2021 (he was on extension for 2019) but he failed to file a personal tax return for 2020. On March 1, 2022, an IRS agent showed up at the Chocolate Factory and asked Willy if he had control over a bank account outside of the United States, and Willy said no.

Willy was last seen at Never Never Land Bank withdrawing $50,000 cash from the bank account held in the name of Oompa Loompa.

Question 2 of 4:

As the Special Agent, you have the ear of the federal prosecutor. What charges would you recommend be brought against Willy Wonka? Discuss the advantages and disadvantages of each of the potential charges. You may wish to reference ambiguities that you hope to resolve through the information-gathering you discussed in response to Question 1.

• If you need question 1 Please go back to the previous question I asked last night.
• Please do not provide an answer that already submitted.
• Elaborate on the questions like an essay question in total 1000 words.