The IRS Dirty Dozen: When Tax Planning Becomes Tax Fraud

Darren P. Wurz, MSFP, CFP®, CEPA® | Wurz Financial Services

Darren P. Wurz, MSFP, CFP®, CEPA®, is the Founder and CEO of Lawyer Millionaire Wealth Advisors, where he works exclusively with law firm owners on business planning, cash flow management, tax strategy, long-term personal financial planning, and investment management. A fiduciary and fee-only advisor, Darren specializes in the unique financial planning needs of attorneys and law firm owners across the country, drawing on his experience as a small business owner to better serve solo practitioners and small firms. He is the author of The Lawyer Millionaire®: The Complete Guide for Attorneys on Maximizing Wealth, Minimizing Taxes, and Retiring with Confidence, published by the American Bar Association, and the host of The Lawyer Millionaire® Podcast. Darren holds a Master of Science in Financial Planning from Golden Gate University and is both a Certified Financial Planner™ professional and a Certified Exit Planning Advisor®. His mission is to help attorneys achieve financial independence as they define it.

Education & Credentials

• Darren P. Wurz holds a Master of Science in Financial Planning from Golden Gate University. He is a Certified Financial Planner™ (CFP®) professional and a Certified Exit Planning Advisor® (CEPA®), credentials that reflect his formal training and specialization in comprehensive financial and exit planning strategies.

Recognition & Leadership

• Darren is the Founder and CEO of Lawyer Millionaire Wealth Advisors, a firm dedicated exclusively to serving law firm owners. He is the author of The Lawyer Millionaire®: The Complete Guide for Attorneys on Maximizing Wealth, Minimizing Taxes, and Retiring with Confidence, published by the American Bar Association, and he serves as host of The Lawyer Millionaire® Podcast.

Professional Involvement

• Darren is an active member of the American Bar Association and the Financial Planning Association. He is also involved locally as a member of the Cincinnati Bar Association, the Northern Kentucky Bar Association, and the Covington Business Council.

Experience

• Darren specializes in financial planning for attorneys and law firm owners nationwide, providing guidance in business planning, cash flow management, tax strategy, long-term financial planning, and investment management. As a fiduciary and fee-only advisor, he focuses exclusively on the unique needs of legal professionals, drawing from his own experience as a small business owner. His office is located in Cincinnati, Ohio, and he was born and raised in Toledo, Ohio.

Jim Koford, CFP®, RICP®, TPCP® | Wurz Financial Service

James Koford, CFP®, RICP®, TPCP®, is the Lead Financial Planner at Wurz Financial Services, and is located near Tampa, Florida. He focuses on tax planning, retirement planning, and investment management, and taxes a planning-first approach that brings structure, clarity, and confidence to clients’ financial lives. James translates complex financial decisions into practical strategies that align investments, cash flow, tax planning, and long-term goals within a cohesive framework. Prior to his current role, he built a diverse career spanning financial planning, investment management, financial education, portfolio strategy, and long-term client relationship management.

Education & Credentials

• James has been a CERTIFIED FINANCIAL PLANNER™ professional since 2014. He also holds the Retirement Income Certified Professional (RICP®) credential and is one of just a few hundred financial planners to hold the Tax Planning Certified Professional (TPCP®) designation. He earned both his Master of Business Administration and his Bachelor’s degree from the University of South Florida.

Recognition & Leadership

• At Wurz Financial Services, James serves as Lead Financial Planner and is known for a thoughtful, disciplined planning process centered on clients’ values, behavior, and sound analysis. Earlier in his career, he contributed to the financial planning profession as an editor at Kitces.com, helping shape widely read industry content on best practices and advisor development.

Professional Involvement

• James is affiliated with the CFP Board and is a member of the National Association of Personal Financial Advisors (NAPFA). He is committed to helping his clients achieve their financial goals.

Experience

• James’s professional background includes direct advisory work with clients, portfolio strategy support, financial education, and long-term client relationship management. His experience spans translating complex planning issues into practical strategies that integrate investments, cash flow, tax considerations, and long-term goals. He works with clients navigating career transitions, retirement preparation, and broader financial life planning decisions.

I. Program framework and context | 1:00pm – 1:12pm

This segment establishes the urgency of tax fraud risks for law firm owners amid rising aggressive tax promotion. It explains why high-income attorneys are prime targets and how social media–driven strategies increase exposure. The focus is on recognizing red flags and protecting your firm, license, and reputation—not exploiting loopholes.

II. Learning objectives | 1:12pm – 1:24pm

Participants will learn to distinguish legitimate tax planning from abusive or fraudulent schemes. The topic highlights common red flags, including those reflected in the IRS “Dirty Dozen,” and the risks tied to them. Attorneys will leave with a practical framework for evaluating tax advice before implementation.

III. Setting the foundation: Tax planning v. tax fraud | 1:24pm – 1:36pm

This section clarifies the legal boundary between tax avoidance and tax evasion, including substance-over-form and economic substance principles. It explains why “gray area” thinking creates significant civil and criminal exposure. Participants will understand why responsibility ultimately remains with the taxpayer, not the advisor.

IV. Why law firm owners are prime targets | 1:36pm – 1:48pm

This segment explores why high-income attorneys are frequently targeted by aggressive tax promoters. It examines psychological drivers, authority bias, and marketing tactics such as urgency and guaranteed results. Attorneys will learn how complexity and entity structuring are often used to create false legitimacy.

V. The IRS Dirty Dozen: High level guideline | 1:48pm – 2:00pm

This section reviews the IRS’s annual “Dirty Dozen” and why it remains central to enforcement efforts. It highlights schemes commonly impacting law firm owners, from conservation easements to ERC abuse. The discussion explains how enforcement unfolds and the financial and legal consequences that follow.

Break | 2:00pm – 2:10pm

VI. Consequences of getting it wrong | 2:10pm – 2:25pm

This segment outlines the financial impact of back taxes, interest, and penalties that can rapidly multiply liability. It also addresses civil and criminal exposure, extended audits, and reputational harm. Attorneys are reminded that reliance on an advisor does not eliminate responsibility.

VII. Practical risk assessment framework | 2:25pm – 2:40pm

Participants are introduced to a defensibility test for evaluating tax strategies before implementation. The framework examines business purpose, transparency, advisor incentives, and courtroom defensibility. Common warning signs such as excessive complexity and secrecy are also addressed.

VIII. Next steps | 2:40pm – 2:55pm

This section provides practical guidance for attorneys concerned about current or proposed strategies. It outlines how to pause implementation, ask better questions, and seek independent review when appropriate. A downloadable red flag checklist supports proactive risk management.

IX. Conclusion & key takeaways | 2:55pm – 3:05pm

The program closes by reinforcing that tax fraud enforcement is increasing, not decreasing. Sophisticated planning prioritizes defensibility over clever structuring, and complexity does not equal legitimacy. The ultimate goal is long-term protection of wealth, freedom, and professional standing.

X. Q&A | 3:05pm – 3:10pm

The program concludes with an interactive discussion addressing participant-specific concerns. Attorneys can explore real-world applications of the risk framework and clarify enforcement trends. The dialogue reinforces practical judgment and confidence in evaluating tax strategies.