CI Investigation or Criminal Investigation?

In a CI situation, the burden of proof is on the government to prove something on the taxpayer side. But there's also that one extra element to it: wolffulness. A mistake, a mismatch, you know, two nine nines, they're different. It's part of the, it's what makes a crime. When you look at crimes, it has to be willful. They've done this every year for several years. This is not a one time mistake,. This is a ride and not turning over all information to the return prepare, which is classic. They hide the bank account. They tell them about everything else, but that one bank account consistently every single