Notice of Representation and Request for CID Conference
The following two paragraphs should be included in a letter to the Criminal Investigation Division ("CID") as soon as the attorney has been retained by a client who is the target of a CID investigation. The first paragraph restricts the IRS from attempting to contact the client directly during the course of the investigation with respect to matters within the scope of the investigation. The second paragraph guarantees that the representative will be offered at least one conference with CID before the case is recommended for prosecution. At that conference, the nature of the charges being considered, the conclusions reached by CID, and, most importantly, the "criminal numbers" will be revealed to the taxpayer's representative. Please be advised that I represent the captioned taxpayer in accordance with the enclosed power of attorney. In accordance with Internal Revenue Manual Part IX, Section 340, subsection 342.19, you are hereby notified that all contacts with the captioned taxpayer are to be made through me.
Please note that we are requesting a District Office conference in connection with the captioned matter pursuant to Treasury Regulation §601.107(b)(2). Please notify me directly of the time and date of the conference. Thank you for your prompt attention to this matter.
