Criminal Tax Defense
Have two Special Agents from IRS Criminal Investigation knocked on your door or walked into your business? Have you received a grand jury subpoena that appears to relate to a tax or accounting matter? Is that new potential customer actually an undercover Special Agent investigating you and your business?
Treasury agents brought down Al Capone on tax charges when no other law enforcement agency could touch him. When Special Agents from IRS Criminal Investigation dig in, they don’t leave a stone unturned. Even if the government assures you that you are just a witness, witnesses can become targets of federal criminal investigations. Contact Dan for a consultation.
Criminal tax and tax-related charges include but are not limited to:
-
Tax evasion including evasion of assessment and evasion of payment ̶ I.R.C. § 7201
-
Willful failure to collect or pay over tax ̶ I.R.C. § 7202
-
Fraud and false statements ̶ I.R.C. § 7202
-
Fraudulent returns, statements, or other documents ̶ I.R.C. § 7207
-
Attempts to interfere with administration of Internal Revenue Laws ̶ I.R.C. § 7212
-
Aiding and abetting ̶ 18 U.S.C. § 2
-
Conspiracy to defraud the government ̶ 18 U.S.C. § 286
-
False, fictitious, or fraudulent claims ̶ 18 U.S.C. § 287
-
Conspiracy to commit offense or to defraud the U.S. ̶ 18 U.S.C. § 287 (a.k.a. Klein conspiracy)
-
Evading foreign taxes charged as wire fraud ̶ 18 U.S.C.A. § 1343. See Pasquantino v U.S., 544 U.S. 349 (2005)
-
Money laundering ̶ 18 U.S.C. §§ 1956 and 1957
-
FBAR reporting ̶ 31 U.S.C. §§ 5314 and 5322