IRS Criminal Defense
Facing IRS Criminal Investigation? Get an Attorney Before You Say Anything.
An IRS Criminal Investigation is not a civil audit — it is a federal criminal matter. IRS Special Agents are law enforcement officers trained to build cases that lead to prosecution. If you have received a Target Letter, been visited by a Special Agent, or been notified that a grand jury is investigating your finances, you need an experienced criminal tax attorney immediately. Do not speak to IRS agents without counsel. Anything you say will be used against you.
What Is an IRS Criminal Investigation?
IRS Criminal Investigation (CI) is the law enforcement division of the IRS. CI special agents investigate tax fraud, tax evasion, money laundering, FBAR violations, unreported foreign income, and related financial crimes. Unlike a civil audit — which results in additional taxes, penalties, and interest — a criminal investigation can result in federal indictment, prosecution, fines, and imprisonment. CI investigations typically begin with information gathered through civil audits, whistleblowers, bank reports, or referrals from other federal agencies. Once CI opens a case, the standard of proof shifts and your rights change dramatically. The Fifth Amendment protection against self-incrimination becomes critical. Never attempt to negotiate directly with CI agents, provide documents voluntarily, or assume cooperation will help your case without first consulting a criminal tax attorney.
How It Works
Emergency Consultation
We meet with you immediately — often same day — to assess what the IRS knows, what you may be facing, and what must be done right now to protect you.
Preserve Your Rights
We immediately invoke your Fifth Amendment rights, notify the IRS and any other agencies that you are represented by counsel, and cut off all direct contact.
Case Investigation & Strategy
We conduct our own investigation, review all documents and financial records, and build a comprehensive understanding of the government's likely theory before formulating a defense strategy.
Pre-Indictment Negotiation
The best outcomes in criminal tax cases are often achieved before indictment. We engage with the DOJ Tax Division and CI directly to present mitigating facts and negotiate civil resolution where possible.
Trial Defense if Necessary
If the case proceeds to indictment, our attorneys provide full criminal trial defense in federal court — challenging evidence, cross-examining witnesses, and fighting for the best possible outcome.
Who Should Consider This?
- ✓Received a Target Letter from the IRS or DOJ Tax Division
- ✓Visited or contacted by an IRS Special Agent
- ✓Named in a grand jury subpoena for financial records
- ✓Under investigation for unreported income, offshore accounts, or FBAR violations
- ✓Facing civil fraud penalties that may escalate to criminal referral
- ✓A business owner whose company is under payroll tax fraud investigation
Key Benefits
Immediate Legal Protection
The moment we are retained, all IRS and DOJ contact goes through us. You stop speaking to agents — period.
Pre-Indictment Resolution
Many criminal investigations are resolved civilly before charges are filed when represented by an experienced criminal tax attorney early enough.
Fifth Amendment Defense
We ensure your constitutional rights are preserved at every stage of the investigation, preventing self-incriminating statements from being used against you.
Minimize Exposure
Even in cases that proceed to prosecution, skilled representation can mean the difference between probation and prison, or between a misdemeanor and a felony.
Ready to Resolve Your IRS Criminal Defense Issue?
Free consultation. No obligation. A licensed tax attorney will call you within 5 minutes.
Frequently Asked Questions
What is a Target Letter from the IRS?+
A Target Letter is formal notification from the Department of Justice Tax Division that you are the target of a federal grand jury investigation. It is one of the most serious notices you can receive — it means prosecutors believe they have sufficient evidence to charge you. You have the right to have an attorney present before any grand jury testimony. Call us immediately if you receive one.
Should I cooperate with IRS Special Agents?+
No. You should politely decline to speak with IRS Special Agents and immediately contact a criminal tax attorney. Special Agents are trained investigators — their goal is to gather evidence for prosecution. You have an absolute Fifth Amendment right to remain silent. Exercise it.
Can a criminal tax case be resolved without prosecution?+
Yes — and the best outcomes are often achieved before indictment. When experienced criminal tax attorneys engage with CI and the DOJ early, there is often an opportunity to present mitigating facts, correct reporting errors, or reach a civil settlement that avoids criminal charges entirely. This window closes once an indictment is filed.
What is the penalty for tax evasion?+
Federal tax evasion under 26 U.S.C. § 7201 carries a maximum sentence of 5 years in federal prison and fines up to $250,000 per count. Tax fraud carries up to 3 years. FBAR willful violations can add additional criminal exposure. The earlier you retain a criminal tax attorney, the better your chances of avoiding the most serious consequences.
What is the difference between a civil audit and a criminal investigation?+
A civil audit is conducted by IRS revenue agents and results in tax assessments, penalties, and interest. A criminal investigation is conducted by IRS Special Agents (who are law enforcement) and can result in federal prosecution and imprisonment. The moment you believe your civil audit may have criminal exposure — especially if agents start asking about intent — you need a criminal tax attorney immediately.
Related Services
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IRS Levies
An IRS levy gives the government the legal right to seize your assets. We act fast to release levies on bank accounts, wages, Social Security, and property.