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So your probably staring at this IRS summons demanding every financial record you’ve touched in the last six years and your hands are literaly shaking. Maybe they think you underreported income. Maybe someone reported you for tax fraud. Or maybe your just caught up in there latest enforcement initiative. Look, we get it. Your ABSOLUTELY PANICKED. And you should be! Because IRS Criminal Investigation has a 90% conviction rate and tax fraud means FEDERAL PRISON!
Let me explain the nuclear weapon your facing. The IRS has incredibly broad summons authority to demand documents, records, and testimony about ANY matter “relevant or material” to there investigation. And here’s what’s terrifying – they define “relevant” so broadly that literally EVERYTHING in your financial life is fair game!
Unlike a regular audit notice, an IRS summons means they think something criminal is happening. This isn’t about adjusting your tax bill anymore – its about building a case to put you in federal prison! The summons is usualy the first step in what becomes a criminal investigation by IRS Criminal Investigation Division (CI).
The really scary part? The IRS can issue summonses to ANYONE – your bank, your accountant, your business partners, your employees, even your family members! They’re building a complete picture of your financial life from every angle!
Sit down before reading this because the penalties will make you physically ill. Tax evasion under 26 USC § 7201 carries up to 5 years in federal prison and $250,000 in fines ($500,000 for corporations). But that’s PER COUNT!
Filing false returns (26 USC § 7206) adds another 3 years per return! Failure to file returns? Another 1 year per return! Conspiracy to defraud the IRS? 5 more years! We’ve seen taxpayers facing 20-30 years in prison for what started as “simple” tax disputes!
But here’s what’s really devastating – the financial destruction! Criminal tax convictions mean paying back taxes, interest, civil fraud penalties (75% of tax owed), criminal fines, prosecution costs, and asset forfeiture! One client owed $500,000 in taxes but after criminal conviction faced $3 MILLION in total liability!
Your probably wondering “Why me? Everyone cheats on taxes!” Let me tell you what puts people in CI’s crosshairs:
Information from civil audits gets referred to Criminal Investigation when auditors find “badges of fraud” – unreported income, false deductions, altered documents, or hidden assets. Whistleblowers get up to 30% of what IRS collects – your ex-spouse, business partner, or employee can get rich by destroying you!
Bank Secrecy Act reports trigger investigations – deposits over $10,000, suspicious transactions, or structuring to avoid reporting. Even legitimate business activity gets flagged! Related civil litigation exposes tax issues – divorce proceedings, business disputes, bankruptcy filings all get IRS attention. We’ve seen criminal investigations start from routine traffic stops where cops found business receipts!
This is critical to understand! Civil and criminal investigations run parallel but separate. You could be dealing with both simultaneously without knowing it!
Civil investigations focus on collecting taxes – they want your money. Criminal investigations focus on prosecution – they want you in PRISON! But here’s the trap: information from civil proceedings feeds criminal investigations. That innocent explanation you gave the revenue agent? Now it’s evidence of willful tax evasion!
Once a criminal referral is made to DOJ, the IRS can’t issue new summonses for that tax period. But by then, they already have everything they need to destroy you! We’ve seen taxpayers cooperate fully with “civil” audits only to get arrested six months later based on there own statements!
NO! ABSOLUTELY NOT! Ignoring an IRS summons is the worst thing you can do! The IRS will immediately go to federal court for enforcement. The judge WILL order compliance. You’ll be held in contempt of court. You could be jailed until you comply!
But even worse, ignoring a summons makes CI assume your hiding massive fraud. They’ll get search warrants, freeze your accounts, and accelerate criminal charges. We had a client who ignored a summons thinking it would “go away.” Six months later, 20 IRS agents raided his business, home, and storage units simultaneously!
The only legal way to challenge a summons is through proper procedures – claiming privilege, arguing relevance, or showing undue burden. But these defenses are extremely limited and require expertise most lawyers don’t have!
NEVER! If CI contacts you, the ONLY words out of your mouth should be “I want my lawyer!” CI special agents are trained criminal investigators with one goal – putting you in federal prison!
These aren’t accountants with badges – there federal law enforcement agents who carry guns, execute search warrants, and make arrests! They’re trained in interrogation techniques designed to get confessions. That “friendly chat” to “clear things up”? Its a recorded interrogation building your prosecution!
Even truthful statements can destroy you! “I thought that was deductible” becomes evidence of knowledge. “My accountant said it was okay” becomes evidence you knew it was questionable. “I was planning to amend” becomes admission of filing false returns! There’s literally no safe answer except silence!
Here’s something that’ll make you sick – accountant-client privilege is VERY limited! The IRS can force your CPA to testify against you!
Only Federally Authorized Tax Practitioners (attorneys, CPAs, enrolled agents) have limited privilege under Section 7525. But it doesn’t cover: tax return preparation, business advice, or criminal matters! Your accountant’s workpapers, emails, and notes are all fair game!
Even attorney-client privilege has exceptions! The crime-fraud exception means if you consulted a lawyer to commit fraud, there’s no privilege! We’ve seen the IRS pierce privilege by claiming the client sought advice to evade taxes. Your own lawyer’s files become evidence against you!
Buckle up for YEARS of torture. IRS criminal investigations are notoriously long and thorough:
Initial summons and document review (3-6 months), expanded investigation with multiple summonses (6-12 months), CI special agent investigation (12-24 months), referral to DOJ Tax Division (6-12 months), grand jury and indictment (3-6 months), trial or plea negotiations (12-24 months). Your looking at 3-6 years of hell minimum!
During this time, your life is frozen. Banks report every transaction to IRS. Business associates distance themselves. Professional licenses get suspended. Travel is restricted. And legal fees? Expect to pay $500,000 to $1 million for a criminal tax defense!
The IRS has a voluntary disclosure program, but its a TRAP for the unwary! DOJ must approve criminal tax prosecutions, and voluntary disclosure is a factor – but NOT a guarantee!
To qualify, disclosure must be: truly voluntary (before IRS contacts you), complete and accurate, and include payment arrangements. But here’s the catch – if IRS already knows about you from a bank report, whistleblower, or information sharing, your disclosure isn’t “voluntary” anymore!
We’ve seen taxpayers attempt voluntary disclosure only to get prosecuted anyway because IRS already had there name from a foreign bank disclosure. One client tried to come clean about offshore accounts – he’s serving 3 years in federal prison because his disclosure was one day too late!
Look, we’re not your typical tax lawyers who file offers in compromise. We’re criminal defense attorneys who specialize in keeping people out of federal prison when IRS investigations turn criminal. We understand both tax law AND criminal procedure.
We know how to respond to summonses without providing ammunition for prosecution. We can identify when civil audits are really criminal investigations in disguise. We understand CI’s investigation techniques and how to counter them. Most importantly, we know how to negotiate with DOJ Tax Division to avoid prosecution!
Other firms tell you to cooperate and show good faith. That’s EXACTLY what gets people convicted! The IRS has a 90% conviction rate because people try to explain there way out of trouble. We fight strategically, using every legal protection while building your defense from day one!
Call us RIGHT NOW at 212-300-5196
IRS Criminal Investigation moves FAST – don’t wait!
Free consultation – Former federal prosecutors on staff – Available 24/7!
Don’t wait another second! Every day you delay is another day CI builds there case. There interviewing your business associates, analyzing your bank records, preparing search warrants. The walls are closing in and you don’t even know it!
Remember – the IRS has unlimited resources, a 90% conviction rate, and zero mercy for tax criminals. You need someone who knows how to fight the most powerful collection agency in the world. Call us NOW before that summons becomes handcuffs!
Very diligent, organized associates; got my case dismissed. Hard working attorneys who can put up with your anxiousness. I was accused of robbing a gemstone dealer. Definitely A law group that lays out all possible options and best alternative routes. Recommended for sure.
- ROBIN, GUN CHARGES ROBIN
NJ CRIMINAL DEFENSE ATTORNEYS