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26 U.S.C. § 7212 – Interference with tax administration

If you’re reading this – you’re in serious trouble. Federal tax obstruction charges under 26 U.S.C. § 7212 aren’t something you can talk your way out of. You’re facing up to 3 years in federal prison – and that’s just the beginning. The federal government has a 90.6% conviction rate in tax cases. Let that sink in. Over 90% of people charged with federal tax crimes end up convicted. You don’t have time to waste researching lawyers online – you need the best criminal defense attorney, ASAP.

At Spodek Law Group – we’re not your average criminal defense law firm. We’re a premier, top rated federal criminal defense firm with over 50 years of combined experience. Our attorneys, have handled some of the toughest cases nationwide – coast to coast. We get it – you’re terrified, and you should be. Federal prosecutors don’t mess around when it comes to tax obstruction charges. They have virtually unlimited resources, and they’re coming after you.

Understanding 26 U.S.C. § 7212 – What You’re Really Facing

So, what exactly is tax obstruction under Section 7212? This federal statute makes it a crime to corruptly or by force interfere with the administration of internal revenue laws. The law has two parts – the Officer Clause and the Omnibus Clause. Most people, get charged under the Omnibus Clause – which covers any corrupt attempt to obstruct or impede the IRS.

Here’s the thing – after the Supreme Court’s decision in Marinello v. United States, prosecutors now have to prove you knew about a specific IRS proceeding, like an audit or investigation. But don’t get too comfortable. The government, still wins these cases over 90% of the time. They know how to prove you were aware of an IRS investigation – even if you think you covered your tracks.

The penalties are severe. You’re looking at:

• Up to 3 years in federal prison
• Fines up to $5,000 (but often much higher with additional charges)
• A permanent federal criminal record
• Loss of professional licenses
• Destruction of your reputation and career

Todd Spodek – a second-generation attorney who has represented many high-profile clients, including Anna Delvey (featured in the Netflix series) – understands the stakes. Our rock star team of criminal attorneys know a thing or two about beating federal charges. We’ve handled thousands of tough cases, and we’re not afraid to take on the DOJ.

The Reality of Federal Tax Prosecutions

You’re not dealing with state court here. Federal prosecutors have a 90.6% conviction rate. That means if you’re charged – you’re probably going to be convicted unless you have the best possible legal representation. Most attorneys, don’t understand federal tax law. They don’t know the complexities of Section 7212. They don’t have experience fighting the IRS and DOJ.

We’re different. At Spodek Law Group – we focus on federal criminal defense. Our nationwide practice means we can represent you anywhere in the country – coast to coast. We’re available 24/7 because we understand that federal investigations don’t follow business hours. When the FBI shows up at your door at 6 AM – you need an attorney who will answer the phone.

The average sentence for tax crimes is 16 months in federal prison. But that’s just the average. If you obstructed an IRS investigation – the judge will likely give you more time. And federal prison isn’t like state prison. There’s no early release for good behavior like you see in the movies. You serve at least 85% of your sentence.

Common Ways People Violate Section 7212

You might think you’re being smart, but the IRS has seen it all. Common violations include:

• Destroying business records during an audit
• Lying to IRS agents during an investigation
• Threatening or intimidating IRS employees
• Creating false documents to hide income
• Instructing others to lie to the IRS
• Moving assets to avoid collection

Each of these actions, can land you in federal prison. The government doesn’t need to prove you succeeded in obstructing the IRS – just that you tried. That’s whatmakes this statute so dangerous. Even an unsuccessful attempt is a federal felony.

Most importantly – you can’t do this alone. Trying to handle a federal tax obstruction case without an experienced attorney is like performing surgery on yourself. It won’t end well. Our premier criminal defense attorneys have the experience and knowledge to fight these charges. We’ve been featured in major media outlets like NY Post, Newsweek, Fox 5, Business Insider, Bloomberg, and others because of our success in tough federal cases.

Why Spodek Law Group Is Different

Unlike other law firms who are more focused on their relationship with prosecutors – we fight for our clients. Many law firms are “mills” and take on every single client. We’re selective. We focus on only working with clients who we can truly help. Our white-glove service means you get personal attention from top rated attorneys, not paralegals or junior associates.

We have over 50 years of combined experience handling federal criminal cases. We’re one of the few law firms in the country have a completely online digital portal where you can track your case 24/7. Our attorneys are available nationwide – from NYC to Los Angeles, we can help you regardless of where your case is in the USA.

Todd Spodek is a second-generation attorney who learned the practice of law from his father. He’s handled some of the toughest cases in the country. When Netflix wanted to make a series about one of his clients – Anna Delvey, also known as Anna Sorokin – they chose Todd’s case because of the fascinating legal strategy involved. We argued that Sorokin’s behavior was not criminal but rather reflective of the culture of New York’s elite.

The Federal Investigation Process

If you’re under investigation for violating Section 7212 – the government is building a case against you right now. IRS Criminal Investigation (CI) special agents are trained financial investigators. They’re following your money, analyzing your bank records, and interviewing witnesses. By the time you know you’re under investigation – they’ve been working on your case for months, maybe years.

The investigation process typically involves:

• Review of tax returns and financial records
• Bank account analysis
• Interviews with business associates and employees
• Surveillance and monitoring
• Grand jury subpoenas
• Search warrants

Each step of this process – is an opportunity for you to make things worse. Talking to agents without an attorney, destroying documents, or lying about your activities will only add charges. You need an attorney who understands federal criminal procedure and can protect your rights throughout the investigation.

Defense Strategies for Section 7212 Charges

At Spodek Law Group – we don’t just accept what the government says. We fight back with sophisticated defense strategies tailored to your specific situation. Every case is different, and we develop customized approaches based on the facts and evidence.

One critical defense involves challenging the government’s proof that you knew about a specific IRS proceeding. Thanks to the Marinello decision, prosecutors can’t just claim you obstructed the general administration of tax laws. They must prove you knew about an audit, investigation, or other specific proceeding. This requirement – gives us ammunition to fight the charges.

Another defense strategy focuses on the “corrupt” intent requirement. Not every interaction with the IRS that goes poorly constitutes criminal obstruction. We can argue that your actions, while perhaps misguided, weren’t corrupt. Maybe you were confused, scared, or receivingbad advice from someone else. These circumstances don’t make you a criminal.

We also examine whether the government can prove all elements of the offense beyond a reasonable doubt. Federal prosecutors often overcharge cases, hoping defendants will plead guilty out of fear. Our top rated criminal defense attorneys know how to identify weaknesses in the government’s case and exploit them at trial.

Sometimes, the best defense is challenging the investigation itself. If IRS agents violated your constitutional rights – such as conducting illegal searches or coercing statements – we can move to suppress evidence. Without key evidence, the government’s case may fall apart.

The Importance of Early Intervention

The biggest mistake people make is waiting too long to hire an attorney. By the time you’re indicted – it’s often too late to implement the best defense strategies. If you suspect you’re under investigation, or if you’ve been contacted by IRS-CI agents – you need to call us immediately.

Early intervention allows us to:

• Communicate with prosecutors before charges are filed
• Potentially avoid criminal charges through civil resolution
• Preserve evidence that helps your defense
• Prevent you from making incriminating statements
• Guide you through the investigation process

Regardless of the situation you find yourself in, know that our criminal defense attorneys can help you. We’ve seen it all – from small business owners who made mistakes to sophisticated tax schemes involving millions of dollars. No case is too complex or challenging for our experienced team.

What Makes Tax Obstruction Different from Tax Evasion

Many people confuse tax obstruction with tax evasion, but they’re different crimes with different penalties. Tax evasion under 26 U.S.C. § 7201 involves willfully attempting to evade taxes. Tax obstruction involves interfering with the IRS’s ability to do its job.

You can be charged with both crimes from the same conduct. For example, if you file false returns (evasion) and then lie to IRS agents investigating those returns (obstruction) – you’re facing multiple felony charges. The government loves to stack charges because it gives them leverage in plea negotiations and increases potential sentences.

The key difference is timing. Tax evasion typically occurs when you file false returns or fail to file at all. Tax obstruction happens afterthe IRS starts looking into your tax matters. This distinction – is crucial for developing defense strategies.

The Sentencing Process – What Really Happens

If you’re convicted of violating Section 7212 – sentencing is where the rubber meets the road. Federal judges use the U.S. Sentencing Guidelines to determine your sentence, but they have discretion to go higher or lower based on various factors.

The guidelines consider:

• The tax loss amount (even though 7212 doesn’t require tax loss)
• Whether you used sophisticated means
• Your role in the offense
• Whether you obstructed justice during the case
• Your criminal history
• Whether you accepted responsibility

Our experienced federal criminal defense attorneys know how to present mitigating factors that can reduce your sentence. We’ve helped clients avoid prison entirely, even after conviction. But the best outcome is avoiding conviction in the first place – which is why you need the best possible legal representation.

The federal sentencing process is complex and unforgiving. Judges in different districts have different tendencies. Some are known for harsh sentences in tax cases, while others are more lenient. Our nationwide – coast to coast – practice means we know the judges and prosecutors across the country. This knowledge is invaluable in developing strategies for your case.

Collateral Consequences You Haven’t Considered

A conviction for federal tax obstruction doesn’t just mean prison time. The collateral consequences can destroy your life:

• Loss of professional licenses (CPA, attorney, doctor, etc.)
• Inability to get federal contracts or licenses
• Difficulty finding employment with a federal conviction
• Loss of voting rights in some states
• Immigration consequences for non-citizens
• Damage to business relationships and reputation

These consequences last long after any prison sentence ends. That’s why it’s crucial to fight these charges with everything you’ve got. Our premier criminal defense firm understands what’s at stake. We don’t just focus on keeping you out of prison – we fight to protect your entire future.

Why Time Is Not On Your Side

Every day you wait to hire an attorney is a day the government gets stronger. They’re gathering evidence, interviewing witnesses, and building their case. Meanwhile, you’re sitting at home, hoping this will go away. It won’t.

The statute of limitations for Section 7212 is six years, giving the government plenty of time to investigate and prosecute. But most cases move much faster than that. Once you’re indicted, you typically have only a few months before trial. That’s not enough time to mount an effective defense if you’re just starting to look for an attorney.

Spodek Law Group offers free consultations because we understand you need to make an informed decision. But don’t mistake a free consultation for free time. The clock is ticking on your case, and every day matters. Calll us today – we’re available 24/7 to discuss your case. We get it – you want to know your options before committing, which is why we offer a free consultation to every potential client.

The Bottom Line – Your Future Is In Jeopardy

Federal tax obstruction charges under 26 U.S.C. § 7212 are serious business. You’re facing real prison time, massive fines, and the destruction of everything you’ve worked for. The government has a 90%+ conviction rate because most people don’t have proper representation.

At Spodek Law Group – we level the playing field. Our top rated, premier federal criminal defense attorneys have over 50 years of combined experience fighting the toughest cases. We’re not intimidated by federal prosecutors or IRS agents. We’ve been there before, and we know how to win.

Todd Spodek – a second-generation attorney featured in major media outlets for his work on high-profile cases like Anna Delvey – leads our team. We provide white-glove service with 24/7 availability because we understand that your freedom is on the line.