the Internet can be used to research civil fraud tax cases and criminal fraud prosecutions by the IRS.

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