Tax Evasion Defense Attorney
Federal tax evasion carries up to 5 years in prison per count and $250,000 in fines. IRS Criminal Investigation has a 90%+ conviction rate. You need criminal tax counsel immediately — preferably before you've said a word to any federal agent.
Federal Tax Crimes & Penalties
The IRS can pursue multiple charges from a single set of facts. Each count carries independent penalties.
26 U.S.C. § 7201
Tax Evasion
Willful attempt to evade or defeat federal tax. Most serious tax crime.
Penalty: Up to 5 years + $250,000 fine per count
26 U.S.C. § 7206
Filing a False Return
Knowingly making false statements on a federal tax return.
Penalty: Up to 3 years + $250,000 fine per count
26 U.S.C. § 7203
Failure to File
Willful failure to file a required tax return, pay tax, or keep records.
Penalty: Up to 1 year + $100,000 fine per count
31 U.S.C. § 5322
FBAR Criminal Violation
Willful failure to file FBAR under the Bank Secrecy Act.
Penalty: Up to 5 years + $250,000 fine
18 U.S.C. § 1956
Money Laundering
Financial transactions designed to conceal the proceeds of tax crimes.
Penalty: Up to 20 years + $500,000 fine
Why You Must Act Before Indictment
Pre-Indictment Window
Before indictment, we can engage with the DOJ Tax Division, present mitigating facts, and often negotiate civil resolution — eliminating criminal exposure entirely.
Control the Narrative
The statements you make (or don't make) in the early stages of an investigation become the evidence at trial. We ensure nothing you do helps build the government's case.
Sentencing Mitigation
Even when prosecution cannot be avoided, pre-indictment cooperation under attorney guidance is weighted heavily at sentencing — often the difference between prison and probation.
Frequently Asked Questions
What is the difference between tax avoidance and tax evasion?
Tax avoidance is legal — it means using legitimate deductions, credits, and strategies to reduce your tax liability. Tax evasion is illegal — it means deliberately concealing income, lying on returns, or taking false deductions. The line is intent. The IRS must prove you willfully evaded taxes, not just that you made mistakes. An experienced criminal tax attorney builds the case that your actions were mistakes, aggressive (but legal) tax planning, or reliance on professional advice — not willful evasion.
What triggers an IRS criminal tax investigation?
IRS Criminal Investigation (CI) typically opens cases based on: referrals from civil audit divisions, bank Suspicious Activity Reports (SARs), whistleblower tips (including from disgruntled employees or business partners), information sharing with the DOJ or other federal agencies, or patterns identified through data analytics. CI does not open cases randomly — if you are being investigated, they likely already have substantial information.
Should I try to cooperate and explain my situation to IRS agents?
Absolutely not — not without an attorney. People who cooperate with IRS special agents under the belief that "if I just explain it, they will understand" frequently provide the exact statements that prosecutors use for conviction. Special agents are highly trained investigators. Your right to remain silent is absolute. Exercise it, then call us.
Can tax evasion charges be resolved civilly without prosecution?
Yes — and this is often the best possible outcome. When an experienced criminal tax attorney engages with CI and the DOJ Tax Division early in the investigation, there is frequently an opportunity to resolve the matter civilly — paying back taxes, penalties, and interest without criminal prosecution. This window is often available before indictment but closes once charges are filed. Early intervention is critical.
What happens if I'm convicted of federal tax evasion?
Federal tax evasion conviction under § 7201 carries up to 5 years in federal prison per count, a fine of up to $250,000 per count, the cost of prosecution, restitution of all evaded taxes, and loss of professional licenses in many fields. If your case involves multiple years or multiple counts, sentences can be consecutive. Skilled defense, plea negotiation, and mitigation at sentencing are critical.
Pick a Time That Works for You
Free 30-minute consultation with a licensed tax specialist. No pressure, no obligation.