Tax Rep Network with Eric Green

Eric L. Green, Esq. - National Speaker and Author

Join Eric L. Green with Tax Rep Network and build your practice. Navigate the ins-and-outs of IRS Collections, Offers-in-Compromise, Reducing IRS Penalties, etc. Turn this hottest of growth areas into a revenue stream for your practice and help hundreds of people resolve their worst nightmare!

  1. Inside A Criminal Tax Case Part 2 With John Mulcahy

    May 21

    Inside A Criminal Tax Case Part 2 With John Mulcahy

    In Part 2 of this deep-dive series, Eric Green is joined again by former U.S. Department of Justice Tax Division attorney John Mulcahy for an unfiltered look at what really happens behind the scenes in a criminal tax case. This episode pulls back the curtain on the critical decision-making process inside the government—from how cases are reviewed and approved for prosecution to the high bar prosecutors must meet under the “reasonable probability of conviction” standard. John walks through what happens when IRS agents submit a case, how DOJ attorneys analyze evidence, and why some cases get sent back for further development before charges are ever filed. Eric and John also tackle one of the most important (and misunderstood) opportunities for defense attorneys: the pre-charging conference with the DOJ. They explain why these meetings matter, how they can change the trajectory of a case, and what prosecutors are really looking for before deciding whether to move forward with criminal charges. The conversation then shifts to strategy—covering proffers, reverse proffers, and how both sides use these tools to either build or defend a case. You’ll hear real-world examples of how these interactions play out, including when they lead to declined prosecutions… and when they don’t. Finally, the episode explores the realities of sentencing, restitution, and negotiation dynamics—breaking down how numbers drive outcomes, why simplicity matters in front of a jury, and how acceptance of responsibility can significantly impact a client’s future. Whether you’re a tax professional, attorney, or advisor, this episode delivers practical insight into navigating criminal exposure, advising clients effectively, and understanding how the government thinks at every stage of a case. If you haven’t listened to Part 1 yet, start there—this is a continuation you won’t want to miss. Want to contact John? Email him at: jmulcahy@nixonpeabody.com.

    50 min
  2. Inside A Criminal Tax Case With John Mulcahy

    May 18

    Inside A Criminal Tax Case With John Mulcahy

    What really happens when a tax case goes criminal? In this episode of the Tax Rep Network Podcast, host Eric Green sits down with former federal prosecutor John Mulcahy—now in private practice at Nixon Peabody—to pull back the curtain on how criminal tax cases are built, reviewed, and prosecuted. Drawing on over a decade of experience at the U.S. Attorney’s Office and the DOJ’s tax division, John walks through the lifecycle of a criminal tax case—from initial IRS investigation to DOJ review, grand jury proceedings, and ultimately, prosecution decisions. Along the way, he explains why the DOJ still plays a critical gatekeeping role and how consistency in tax enforcement is maintained nationwide. But this conversation goes beyond process. Eric and John dig into the real-world dynamics that shape outcomes: the discretion of Assistant U.S. Attorneys, the strategic decisions behind charging (or declining) a case, and the often misunderstood role of “willfulness” in tax crimes. Through candid stories and behind-the-scenes insights, they highlight how cases can turn on a single issue—especially intent—and why listening closely to clients can make or break a defense. Now on the defense side, John also shares what it’s like transitioning from prosecutor to advocate—working with clients in crisis, navigating complex facts, and seeing firsthand that every case has more than one side. If you’re a tax professional, attorney, or anyone curious about how criminal tax enforcement really works, this episode offers a rare insider perspective you won’t hear anywhere else. Want to contact John?  Email him at: jmulcahy@nixonpeabody.com

    25 min
4.9
out of 5
172 Ratings

About

Join Eric L. Green with Tax Rep Network and build your practice. Navigate the ins-and-outs of IRS Collections, Offers-in-Compromise, Reducing IRS Penalties, etc. Turn this hottest of growth areas into a revenue stream for your practice and help hundreds of people resolve their worst nightmare!

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