Criminal Tax Investigation
& Trial

Criminal Defense AttorneyWhen Citizens and Businesses Become IRS “Targets”

In 2009 according to the IRS, over 90% of the individuals that the IRS’s Division of Criminal Investigation (known as “CI”) got indictments or information against were convicted.  In fact, the IRS brags that the CI Division’s “conviction rate is one of the highest in the federal law enforcement community.”  The average prison sentence was 46 months, which is almost 4 years.  Imprisonment and a prison record does not stop the piling on of fines, civil taxes, and penalties.

IRS Criminal Tax Investigation

Often, the IRS investigation quietly proceeds for years before the IRS has the hangman’s noose ready to go over the citizen’s head.  Late in the process, the “targeted” individual or company sometimes receives a letter from the IRS which states something along the following lines: “…you are the subject of a criminal tax investigation.”  These are some of the other signs:

  • IRS-goes-after-you.jpgIRS Special Agent. You have been contacted by an IRS Special Agent (or "IRS SA"), who probably tried to catch you off guard with an interview or before you’ve had a chance to consult with counsel.
  • IRS, DOJ, & U.S. Attorney. Your bank, brokerage firm or other financial institution has been contacted by the IRS, Department of Justice Tax Division (or "DOJ Tax"), or U.S. Attorney’s office.
  • Federal Grand Jury Investigation. Your accountant or next door neighbor or ex-spouse has been subpoenaed to appear before a federal grand jury and give testimony.  It won't be fair.  And everyone is in danger.  The witness is not allowed to have a lawyer go inside the Grand Jury Room with her.  And she might be a target.  It is controlled by the United States Attorney.  
  • Tax Audits. You receive a notice from the IRS that your tax returns are being audited and you understated income or overstated deductions or someone is just curious about you.
  • IRS Search or Raid. The IRS has raided your home or office… or questioned your clients/business associates, friends, or family about you.  If you believe, as most citizens do, they never bring guns and make threats in non-violent situations you are new to this area of law.  

Criminal Tax Trial

The bottom line is this.  The more quickly you try to stop the progressive prosecution, the greater your chance of avoiding a criminal trial.  But, if you are persecuted, you need everything possible working in your favor to beat the IRS’s over 90% success rate.