Former IRS Prosecutor Now Protecting You from Criminal Tax Charges
$500M+ Resolved
Tax Disputes
1,000+ Cases
Successfully Defended
Former IRS
Criminal Division
IRS Criminal Investigation? Act Now
Special agents at your door? Summons received? Time is critical.
From Netflix Productions to Financial Media - Trusted Tax Crime Expert
Featured Expert
Tax Analysis
IRS Coverage
Tax Law Expert
Criminal Tax
Comprehensive defense against all criminal tax charges
Understanding each stage helps protect your rights
Phase 1
IRS Examination
6-12 months
Civil audit identifies potential criminal issues
Our Action:
Kovel attorney protection, limit disclosure
Phase 2
Criminal Referral
Immediate response needed
IRS Criminal Investigation (CI) takes over case
Our Action:
Invoke rights, engage criminal counsel
Phase 3
Grand Jury Investigation
12-24 months
Subpoenas issued, witnesses interviewed
Our Action:
Strategic compliance, witness preparation
Phase 4
Prosecution Decision
3-6 months
DOJ Tax Division reviews for prosecution
Our Action:
Pre-indictment advocacy, negotiate resolution
Phase 5
Indictment/Information
Trial or plea
Formal charges filed in federal court
Our Action:
Trial preparation or plea negotiation
Understanding the severe consequences of tax fraud convictions
| Tax Crime | Prison Time | Financial Penalties | Additional Consequences |
|---|---|---|---|
| Tax Evasion (26 USC 7201) | Up to 5 years prison | $250,000 individual / $500,000 corporate | Prosecution costs, interest, penalties |
| Tax Fraud (26 USC 7206) | Up to 3 years prison | $100,000 individual / $500,000 corporate | Civil fraud penalty 75% of underpayment |
| Failure to File (26 USC 7203) | Up to 1 year prison | $25,000 individual / $100,000 corporate | Civil penalties up to 25% of tax due |
| FBAR Willful Violation | Up to 10 years prison | Greater of $100,000 or 50% of account | Per account, per year penalties |
| Employment Tax Fraud | Up to 5 years prison | Trust fund recovery 100% of tax | Personal liability for responsible persons |
Real cases, real wins, real freedom preserved
Negotiated misdemeanor plea for business owner facing 20 years, proved good faith reliance on accountant
Avoided prison, paid civil penalties only
Converted criminal investigation to civil voluntary disclosure for inherited foreign accounts
No criminal charges, 50% penalty reduction
Won acquittal for CFO by proving no willful failure to pay employment taxes
Avoided personal liability and prison
Secured DPA for early Bitcoin investor with $10M unreported gains
Kept fortune, avoided felony record
Proved preparer was victim of identity theft ring, all charges dropped
Saved professional license and reputation
"High-Net-Worth Executive - $50M Offshore Account Investigation"
Defended Fortune 500 executive with undisclosed Swiss accounts totaling $50 million. Through strategic voluntary disclosure and demonstrating non-willful violations, avoided all criminal charges. Negotiated civil resolution with 90% penalty reduction. Client retained wealth and reputation while achieving full compliance.
Sophisticated approaches from former IRS prosecutors
Proving reasonable belief in tax position legitimacy
Government must prove intentional violation of known duty
Generally 6 years for criminal tax prosecution
Coming forward before investigation starts
Challenge net worth, bank deposits, expenditure methods
When facing the full force of the IRS Criminal Investigation Division
Our lead attorney investigated tax crimes for IRS Criminal Investigation. We know their methods, tools, and strategies.
Deep understanding of tax law, international reporting, cryptocurrency taxation, and sophisticated tax strategies.
Leading expertise in FBAR, FATCA, and offshore voluntary disclosure programs with proven success.
Former IRS agents, forensic accountants, international tax experts, and cryptocurrency specialists on our team.
Featured on Netflix, Bloomberg Tax, WSJ, and CNBC for groundbreaking tax defense victories.
Proper structuring to protect accountant communications and maintain attorney-client privilege throughout.
Critical answers about IRS criminal investigations
IRS criminal investigations require immediate action. Get answers from former IRS agents.
Former IRS prosecutors fighting to protect your freedom and fortune
24/7 Hotline
212-300-5196
Secure Email
tax@federallawyers.com
NYC Office
Manhattan
This website provides general information about tax defense and is not legal or tax advice. Each tax case involves unique facts requiring personalized analysis. Past results do not guarantee similar outcomes. Attorney-client privilege applies only after formal engagement. The IRS Circular 230 disclosure: Any tax advice in this communication is not intended to be used for avoiding penalties under the Internal Revenue Code.
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