This course examines the evolving role of IRS Fraud Technical Advisors (FTAs) and whether their involvement in civil audits raises constitutional or procedural issues under the landmark case United States v. Tweel. We analyze how FTAs coordinate with examiners, identify badges of fraud, and escalate cases toward potential criminal referral—all while maintaining the appearance of a civil examination. Attendees will gain insight into taxpayer rights, disclosure obligations, and how to respond when civil audits shift toward parallel enforcement.