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NTPI Graduate Class: CI / TFRP

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NTPI Graduate Class: CI / TFRP
IRS Program #:
CTEC #: 6257-CE-0156
Speaker: David Gannaway

During this session we will define and discuss Trust Fund Recovery Penalties along with identifying what IRS Criminal Investigation investigative priorities are and how you can assist your clients in both situations.

Who May be Assessed Trust Fund Recovery Penalties TFRP?

  • Define Trust Fund Taxes.
  • Who is a Responsible Person?
  • What are the Willfulness Factors?
  • Preparing a Reasonable Cause Statement

Introduction to IRS Criminal Investigation?
  • What are IRS CI Priorities in Fiscal Year 2023.
  • Describe when a civil tax case potentially rises to a criminal tax investigation.
  • Understand the role of a non-attorney practitioner in a criminal tax investigation
  • Identify when to refer a client to an attorney.


  • David Gannaway, EA, MBA, CFE, CAMS, CVA

    Mr. Gannaway joined J.S.Heldin November 2020 as an executive vice president in the Forensic Accounting & Economics Group. Since 2007, he has been providing tax controversy, litigation support, and expert witness services to attorneys and clients in both civil and criminal litigations in federal and state courts across multiple business sectors including construction, healthcare, financial services, and nonprofit.

    In August 2019, Mr. Gannaway received the distinguished National Tax Practice Institute™ (NTPI®) Fellow designation as recognized by the National Association of Enrolled Agents as an expert in taxpayer representation before the IRS. He frequently represents individuals and business owners under audit and at appeals; prepares reasonable cause statements requesting penalty abatements; and all aspects of collection actions including Form 433A, negotiating installment agreements, and offers in compromise before the IRS and state taxing authorities. 

    As a former IRS criminal investigation special agent and assistant special agent in charge of the New York Field Office, Mr. Gannaway has 20 years of experience in managing and unraveling domestic/international complex white-collar financial fraud schemes involving tax evasion, corruption, and money laundering. He works closely with attorneys as a “Kovel” accountant in defending individuals under investigation or who may have been indicted for alleged white-collar financial crimes.

    Mr. Gannaway is a frequent speaker at industry conferences and a thought leader regarding civil/criminal income taxes, fraud schemes (prevention and detection), regulatory compliance, Bank Secrecy Act, and money laundering.

July 11, 2023
Tue 2:00 PM EDT

Duration 2H 0M

This live web event has ended.