IRS Criminal Defense
Aggressive Defense Against IRS Criminal Investigations and Charges
IRS Criminal Investigation (CI) is one of the most sophisticated law enforcement agencies in the federal government, with a conviction rate exceeding 90%. When CI opens a case against you, the consequences can include prison sentences of up to 5 years, fines of up to $250,000, civil tax penalties on top of criminal fines, and the permanent destruction of your professional reputation and financial life. If you have received any indication that you are under criminal tax investigation, retaining experienced defense counsel immediately is not optional — it is essential.
What Is IRS Criminal Tax Enforcement?
IRS Criminal Investigation (CI) is the law enforcement arm of the IRS responsible for investigating potential criminal violations of the Internal Revenue Code. Common criminal tax charges include: tax evasion (26 U.S.C. § 7201) — intentionally failing to pay taxes owed, carrying up to 5 years imprisonment; filing false returns (26 U.S.C. § 7206) — knowingly filing fraudulent information, up to 3 years; failure to file or pay (26 U.S.C. § 7203) — willful failure to file returns or pay taxes, up to 1 year; and tax fraud conspiracies, money laundering, and structuring violations which carry additional penalties. CI investigations are typically initiated by referrals from IRS auditors, informants, or financial institution suspicious activity reports. The investigation phase often lasts 1–3 years before charges are filed.
How It Works
Immediate Representation
Upon retention, we establish ourselves as your legal counsel with the IRS and Department of Justice. All communications from that point go through us — you do not answer any questions.
Investigation Phase Defense
During the investigation, we monitor the scope of the inquiry, work to limit damaging disclosures, protect privileged communications, and present exculpatory evidence to CI agents.
Grand Jury & Prosecution Response
If your case proceeds to a grand jury or indictment, we challenge the government's evidence, file pretrial motions to suppress, and negotiate with the DOJ Tax Division for the most favorable possible outcome.
Voluntary Disclosure
In some cases, proactive voluntary disclosure to the IRS before an investigation becomes active can significantly reduce or eliminate criminal exposure. We assess whether this strategy is appropriate for your situation.
Trial Representation
If your case goes to trial, our attorneys provide full criminal defense representation including jury selection, cross-examination of government witnesses, and closing arguments focused on reasonable doubt.
Who Should Consider This?
- ✓Anyone who has received a subpoena from a federal grand jury
- ✓Individuals who have been contacted by IRS Criminal Investigation special agents
- ✓Business owners or professionals referred for criminal investigation by civil auditors
- ✓Taxpayers aware of significant discrepancies in prior returns that could be characterized as fraud
- ✓Individuals involved in unreported offshore accounts or foreign financial reporting violations
- ✓Anyone under investigation for tax-related money laundering or currency structuring
Key Benefits
Silence Is Protection
Once we are retained, you say nothing. Everything you say can and will be used against you — we stop that from happening.
Early Intervention
Cases resolved at the investigation stage — before charges are filed — have far better outcomes than those that proceed to prosecution.
Suppress Evidence
Illegal searches, improper procedures, and constitutional violations can result in suppression of key government evidence.
Negotiated Outcomes
Plea negotiations, deferred prosecution agreements, and civil resolution in lieu of criminal prosecution are all possible outcomes we pursue aggressively.
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
Two IRS special agents came to my door. What should I do?+
Do not speak to them under any circumstances. Politely say you will not answer questions without an attorney present, take their business cards, and call us immediately. Anything you say — even seemingly harmless statements — can be used against you.
Can a civil tax problem become a criminal case?+
Yes. Civil IRS auditors are required to refer cases to Criminal Investigation when they find "firm indications of fraud." The line between aggressive tax planning, negligence, and criminal fraud is not always clear — and the IRS agents making those referrals err on the side of criminal referral.
What is the difference between tax evasion and tax avoidance?+
Tax avoidance is the legal use of the tax code to reduce your liability. Tax evasion is the illegal concealment of income, falsification of records, or willful failure to pay taxes owed. The difference is legality and intent — but proving that distinction to a jury is what criminal tax defense attorneys do.
What is the IRS Voluntary Disclosure Program?+
The VDP allows taxpayers to come forward and disclose unreported income or offshore accounts before the IRS discovers them, in exchange for reduced or eliminated criminal exposure. Timing is critical — once an investigation begins, the VDP is no longer available.
Related Services
IRS Audit Representation
Licensed tax attorneys represent you through every type of IRS audit examination to protect your rights and minimize your liability.
Trust Fund Recovery Penalty
When a business fails to remit payroll taxes, the IRS can hold individual owners and managers personally liable. We fight to protect you.
Offer in Compromise
A government-approved program that lets qualifying taxpayers settle their IRS debt for a fraction of the full amount.