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?

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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

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