The Internal Revenue Service issued its 2009 "dirty dozen" list of tax scams, including schemes involving phishing, hiding income offshore and false claims for refunds. "Taxpayers should be wary of scams to avoid paying taxes that seem too good to be true, especially during these challenging economic times," IRS Commissioner Doug Shulman said. "There is no secret trick that can eliminate a person's tax obligations. People should be wary of anyone peddling any of these scams." Tax schemes are illegal and can lead to problems for both scam artists and taxpayers, who risk significant penalties, interest and possible criminal prosecution.