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12 Oct 25

Alabama IRS Tax Fraud Lawyers

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Alabama IRS Tax Fraud Lawyers

You got contacted by IRS Criminal Investigation in Alabama. Or your audit suddenly went quiet and the revenue agent stopped returning calls. Or you know there’s unreported income on your returns and you’re terrified. Here’s what actually happens next in your situation – the real timeline you’re facing, what those 90% conviction rates mean for your case, and why what you say in the next 24 hours might determine whether you spend 15 months or 30 months in federal prison.

Thanks for visiting Spodek Law Group – a second generation law firm managed by Todd Spodek. Our criminal defense attorneys have over 40 years combined experience handling federal cases, including tax fraud investigations where the government has already made up its mind about guilt before they knock on your door. We’ve defended clients in your exact situation. We know what happens when civil audits become criminal investigations, and we know the narrow window you have to make the right moves.

This article explains what happens to YOU when IRS-CI investigates tax fraud in Alabama. Not what the statutes say – what actually occurs in your case. The choices you face when that special agent shows up with a badge. The sentences people in Alabama actually received in 2025. And why cooperation without an attorney isn’t cooperation – its surrender.

When Your Audit Stops Being an Audit

You’re three months into what you thought was a routine audit with an IRS revenue agent. You’ve been providing documents, answering questions, thinking “this is almost over.” Then the agent cancels your next meeting. Won’t return your calls for two weeks. When you finally reach them, they’re suddenly vague about timeline and ask you to answer written questions about your “intent” and “knowledge.” That’s the moment your civil tax dispute became a criminal investigation – you just don’t know it yet.

Here’s what’s happening behind the scenes. The revenue agent found what the IRS calls “firm indications of fraud” – probably an income omission exceeding $10,000 in a single year, which triggers automatic referral under IRS policy. Or they discovered what agents call “badges of fraud”: two sets of books, false invoices, unexplained large bank deposits, inability to explain substantial increases in net worth. The agent has already prepared Form 2797 – Referral Report of Potential Criminal Fraud Cases and submitted it to a fraud technical advisor. That advisor is deciding right now whether to send your case to IRS-CI.

Most people keep talking at this stage. They think: “I’ll just explain the mistakes, clear this up.” That destroys their case. Once questions shift from “how much” to “why” – once the agent asks about your knowledge, intent, or awareness – you’re being evaluated for criminal prosecution. Everything you say goes into Form 2797 and becomes evidence of willfulness. The agent isn’t helping you anymore. They’re building a criminal referral, and you’re providing the rope.

That 90% Conviction Rate

IRS Criminal Investigation doesn’t investigate on hunches. They achieved a 90.4% conviction rate in fiscal year 2024 – 1,571 convictions from 1,794 prosecutions. That’s not because they’re catching the worst criminals. It’s because they only prosecute when conviction is certain. By the time they knock on your door, they’ve already gathered overwhelming evidence through months of investigation you didn’t know was happening.

Recent Alabama cases show what this means. In January 2025, Natoshia Crawford of Montgomery received 30 months in federal prison for filing false tax returns that caused a $1.7 million loss to the IRS. A Mobile woman got 12 months and a day for fraudulent returns. An Alabama chiropractor pleaded guilty to evading $2.5 million and faces up to eight years.

Sentencing under the federal guidelines is driven entirely by tax loss amount. Small losses under $50,000 might result in probation. Losses exceeding $1 million approach or exceed 30 months. The government calculates tax loss using forensic accounting – comparing your reported income to bank deposits, asset purchases, lifestyle expenses. Each dollar you failed to report adds time to your sentence. Your choices aren’t “win versus lose.” With a 90% conviction rate, you’re almost certainly going to be convicted if prosecuted – either through plea agreement or trial. Your real choice is minimizing damage. Early intervention by an experienced federal tax defense attorney can sometimes prevent charges entirely through pre-indictment resolution. After indictment, your options narrow to plea negotiations. The earlier you act, the more leverage you have.

Your Choices When IRS-CI Shows Up

An IRS-CI special agent appears at your door or office. They present credentials with a badge and commission. They identify themselves as criminal investigators and say they want to discuss “discrepancies” in your tax returns. They might read you Miranda rights, or they might just ask if you’re willing to answer some questions “to clear things up.” This is the highest-stakes decision point you’ll face.

What you say in the next 24 hours can determine your sentence length. Here’s what you need to understand: IRS-CI special agents are federal law enforcement officers trained in interrogation techniques. Their goal isn’t collecting taxes – it’s building a prosecution case for the U.S. Attorney’s Office. They already have evidence. The interview isn’t to gather information. It’s to test whether you’ll make incriminating statements that confirm willfulness and criminal intent.

The correct response is simple: “I’d like to consult with an attorney before answering any questions.” Then stop talking. Do not explain. Do not justify. Do not provide documents. Do not agree to “just a few quick questions.” Exercise your Fifth Amendment right to remain silent – politely but absolutely. Then hire a federal criminal tax defense attorney that same day. Not your accountant. Not your CPA. Not a civil tax attorney. You need someone with experience defending federal criminal prosecutions in Alabama.

Most people think cooperation helps. It doesn’t – not at this stage. The government wants you to believe that talking without counsel shows you have nothing to hide. What it actually shows is that you don’t understand the legal jeopardy you’re facing. Cooperation that matters happens through your attorney, who can evaluate the evidence against you, negotiate pre-indictment resolutions with prosecutors, or structure plea agreements that minimize sentencing exposure. Agents won’t offer you those options directly. They’re not authorized to make deals. They’re building a case.

What Happens in Alabama Cases

The investigation takes 1-3 years from opening to indictment. IRS-CI special agents interview everyone in your life – spouse, children, parents, friends, coworkers, employees, business associates, bankers. They subpoena all bank records, credit card statements, investment accounts. They conduct forensic analysis comparing your reported income to bank deposits and asset purchases. They’re building evidence of willfulness – proof you knew you owed tax and intentionally evaded paying it. When the investigation concludes, the special agent prepares a detailed prosecution recommendation that goes through multiple layers of IRS-CI management review before being forwarded to the Department of Justice Tax Division or the U.S. Attorney’s Office for the Middle District of Alabama. With IRS-CI’s 90% conviction rate, most referred cases result in prosecution.

If charges are filed, you face multiple counts – typically one count of 26 U.S.C. § 7201 (tax evasion) per tax year, carrying up to five years per count. About 85-90% of defendants accept plea agreements rather than go to trial. Trial conviction rates exceed 95%. You’ll be sentenced to federal prison – there’s no parole in the federal system, and you must serve at least 85% of your sentence. You’ll owe full restitution to the IRS for the tax loss. You’ll have a permanent felony record affecting employment, professional licenses, and civil rights. And you’ll face 1-3 years of supervised release after prison with monthly reporting requirements.

At Spodek Law Group, we’ve defended federal criminal cases for over 40 years. We understand what you’re facing in Alabama because we’ve handled cases at every stage – from preventing criminal referrals during audits, to negotiating pre-indictment resolutions with DOJ attorneys, to securing favorable plea agreements, to sentencing advocacy that reduces guideline calculations. The IRS gives you enough rope to hang yourself. Revenue agents conduct civil audits while quietly building criminal referrals. You think you’re explaining innocent mistakes – they’re documenting willful fraud. By the time IRS-CI contacts you, talking without counsel isn’t cooperation. It’s surrender. We’re available 24/7 at 212-300-5196.