CRIMINAL TAX INVESTIGATION
We defend Grand Jury criminal investigations and criminal tax prosecutions, where allegations including failure to report income, overstated deductions, failure to file returns and/or the submission of false documentation. We routinely interact with IRS C.I. Special Agents, the Tax Division of the Department of Justice and other federal prosecutors on behalf of individuals and entities who are targets, subjects, or witnesses in criminal tax investigations and prosecutions. We understand the best result is to altogether avoid criminal indictment.
We understand that for many, a criminal tax indictment can be almost as devastating as a conviction. When engaged early enough, we have frequently been successful in presenting factual and legal arguments that have avoided any criminal investigation. In this regard, we prefer to be involved from the earliest stages of any potential investigation to hopefully achieve a non-criminal resolution or, in difficult situations, a resolution that does not include a period of incarceration for our clients. Experience has shown that decisions at the beginning of any investigation can have a positive impact on the final resolution. Similarly, the wrong decisions during an examination or investigation can lead to a disastrous result.
If you or your company may face a potential criminal tax problem, we can help.
We expend every effort to appropriately analyze all relevant facts, explore each and every plausible defense and possible resolution, and respond to issues arising during any investigation or prosecution. Our criminal tax lawyers combine tax knowledge with solid criminal defense experience to provide effective representation throughout the entire process including, when necessary, through plea negotiation or trial and, again if necessary, sentencing and post-sentencing appeals.
Our criminal tax lawyers have represented many individuals and entities nationwide in cases including allegations of failure to file returns and Foreign Bank Account Reports (FBAR), failure to report income, fraudulently overstated deductions, willful failure to pay taxes, failure to collect and pay employment taxes, preparation of false returns, failure to file returns, presentation of false documents to the IRS, conspiracy to impede or obstruct the IRS, as well as other tax-related crimes. We have received many successful resolutions on behalf of our clients facing the most difficult criminal tax problems.