This is the third of three questions on the Midterm. Please read the following fact pattern and respond to the question below. The fact pattern is identical for all four 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 2015, 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 2016, 2017, and 2018 (he was on extension for 2018) but he failed to file a personal tax return for 2019. On March 1, 2020, 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.

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 3 of 4

For this question, assume that you are the forensic accountant hired by Willy Wonka's defense team. What facts would you want to gather to help in Willy's defense? What crimes should Willy's defense team anticipate defending (you may refer back to the analysis in your prior response, but please list the crimes in response to this question)?

What arguments would you suggest Willy's defense attorney make to try to show that Willy is not guilty of these crimes?

• Please do not provide an answer that already posted
• Please do not provide bullet points fully elaborate when answering the question to 1000 words.