Criminal investigations division

Reference no: EM133599414

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:

1. You're the IRS Criminal Investigations Division Special Agent Again. You have to be concerned about potential statutes of limitation.

2. What is the latest date criminal charges could be filed against Willy and for the charges you have discussed?

3. What is the latest date the IRS could assess additional taxes against Willy?

Reference no: EM133599414

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