Criminal Tax Defense Attorney in California

Federal criminal tax cases in Californiaare prosecuted by the DOJ Tax Division in coordination with the United States Attorney's Office for the relevant federal district. IRS Criminal Investigation special agents conduct the underlying investigation — often for months or years — before charges are formally filed.

Unlike civil tax matters, criminal tax cases require proof of willfulness — the government must show you intentionally violated the tax law, not merely that you made mistakes. This is the core of every criminal tax defense. Establishing that your actions were the result of negligence, reliance on a tax professional, or a good-faith misunderstanding of complex tax law is often the difference between prosecution and no charges filed.

The IRS and DOJ are currently prioritizing criminal tax enforcement in several areas: Employee Retention Credit (ERC) fraud, cryptocurrency tax non-compliance, unreported offshore accounts, and abusive tax shelter schemes. If you are in any of these categories, the risk of investigation is elevated significantly.