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Tax Fraud and Tax Crime Defense

The IRS has a separate branch, the IRS Criminal Investigation Division, which is dedicated to investigation of potential and actual tax crimes.  Tax and related crimes include Tax Evasion, Evasion of Payment of Taxes, Fraudulent Failure to Collect Taxes, Fraudulent Failure to Pay Over Collected Taxes, Fraudulent Failure to File a Return, Failure to Supply Information to the IRS, Filing False Returns, False Documents Submission, Money Laundering, Bank Fraud and Mail Fraud.

The consequences of a criminal investigation by the IRS or state tax agency can be very serious, including significant jail time.  That’s why you need an experienced criminal tax attorney who understands both the criminal process and the tax issues involved.  I have all the skills and experience to provide you with aggressive multi-tiered defense.  In many instances, we are able to resolve cases without criminal charges being recommended and convincing the government that no tax crimes were committed.  In instances, where post-indictment defense is necessary, our attorneys will defend you at every step of the process, including trial.

The biggest mistake anyone can make is to underestimate the seriousness of a criminal tax, tax evasion, false return, criminal failure to file or pay, or tax fraud matter. The IRS regularly obtains convictions in over 85% of their criminal tax cases. Under no circumstances should any taxpayer speak with an IRS criminal division Special Agent, without first consulting with an experienced criminal tax attorney.  All statements made by a taxpayer to a Special Agent can be used against him or her in any subsequent court trial. By recognizing early on that you have a potential criminal tax problem, I will have the best chance of arriving at a successful resolution.  If you are facing a criminal tax matter, I can help you.  I am one of the leading criminal tax attorneys in the US.  Put my 30 years of criminal tax law experience to work for you.

Just recently the IRS has put together a special criminal tax task force with the specific mission is to locate those otherwise-good Americans who have (for whatever reason) chosen to use offshore bank accounts such as at UBS bank in Switzerland – to hide US taxable income from the IRS.  The IRS have teamed up with the US Justice Department and they are now aggressively bringing criminal tax charges against any Americans with “secret” offshore bank accounts.  If you are one of these Americans it’s time to seek immediate legal help.

Interesting Facts …

  • The most common way criminal tax investigations get started is by someone reporting you to the IRS for cheating on your taxes.
  • The sole function of an IRS Criminal Division is to obtain sufficient evidence to prosecute you for committing a tax crime.
  • If you are under criminal tax investigation, an IRS Special Agent may make a surprise visit to your home or office. If asked, a criminal Defense attorney would strongly advise that under no circumstances should you speak to the IRS special agent.
  • If you are under criminal tax investigation, the IRS will likely obtain a search warrant to search your home or business.

Taxpayers unfamiliar with the criminal tax process often think that if they just admit their mistakes and offer to pay the additional tax and some penalties, the IRS Special Agent will simply go away. A criminal tax case is very different than a civil tax audit. Admitting any wrongdoings will simply enhance the IRS’s criminal case against you and provide vital evidence which will later be used against you in Court.

While there is attorney-client privilege if a tax attorney completes your tax returns, that same privilege does not extend to CPA’s. There is no CPA-client privilege in a criminal tax case. That means that the CPA or accountant who prepared your tax return can be forced to tell the IRS everything about your tax return and everything you have told him or her.

  • Tax evasion is the willful filing of a false tax return. It is the most serious of all tax crimes.
  • The IRS cannot obtain a conviction for tax evasion if a taxpayer was simply negligent or careless.
  • The IRS cannot obtain a conviction for tax evasion if there is no tax deficiency (even if later determined to be offset by yet-discovered or unused deductions or credits).

If you are concerned that you may have crossed the line into tax fraud the best course of action would be to hire a competent tax attorney to access your situation.

Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney