Criminal Tax Litigation

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Generally, criminal tax litigation can be traced back to the IRS civil audit. Revenue Agents are instructed to suspect fraud in the course of their examination. If an audit unearths a firm indication of fraud, the Revenue Agent will consult with a Fraud Technical Advisor, who will assist the Revenue Agent in developing the case and in determining whether a referral to the Criminal Investigation Division (the “CI Division”) should be made.

The CI Division of the IRS is responsible for all criminal tax investigations, and no case will go forward without first being investigated by the CI Division, even if the criminal investigation is initiated by another federal agency (such as the Federal Bureau of Investigation or the Drug Enforcement Administration). If the CI Division determines that a case should not be forwarded for prosecution, normally you will receive a withdrawal letter. Alternatively, if the CI Division recommends prosecution, you will be notified that the case has been forwarded to the Department of Justice (the “DOJ”).

The DOJ operates under different guidelines than does the CI Division.  The DOJ’s criteria for pursuing a case involve whether the government will prevail in the courtroom in bearing its heavy burden of proof. Even if the DOJ harbors the notion that you may be guilty of a tax crime, flaws in factual development or problems of law may militate against proceeding further. The DOJ has no quota of convictions to be met.

If the DOJ decides to present the case for an indictment, the case is transmitted to the U.S. Attorney for the district in which you reside or in which you conduct your principal business.

Criminal offenses are considered actions such as:

  • Tax evasion.
  • Willful failure to collect or pay over tax.
  • Willful failure to file return, supply information, or pay tax.
  • Submission of false documents and false returns.
  • Attempts to interfere with administration of Internal Revenue laws.
  • Providing false statements.
  • Money laundering.
  • Bribery.
  • Aiding and abetting.
  • And failure to file foreign bank account reporting forms (FBAR).

If you’ve received notification from the CI Division or the DOJ that you are under investigation for a criminal tax offense, you should not attempt to handle the issue on your own.  As a taxpayer whose compliance with the Internal Revenue Code is under dispute, you have the right to legal protection.

Contact a tax attorney at Law Offices of Christy Lee, P.C., immediately, so that our team of tax professionals can protect your best interests with informed, proactive guidance concerning your criminal tax matter.

Why Should You Contact Law Offices of Christy Lee, P.C.?

When facing IRS Audits & Appeals, it's reassuring to have a tax professional on your side that understands the complexities of the law.

As a general rule, taxpayers who seek our legal advice concerning their tax obligations early in the IRS audit achieve substantially more favorable results than those who face such challenges alone.

We ensure that you don't misinterpret questions from the auditors and inadvertently provide information that could be harmful to your case.

You can have supreme confidence in our ability to establish an effective defense for your case due to our collective knowledge regarding the intricacies of tax law.

Tax law routinely updates and changes. For that reason, the team at Christy Lee Law is always up to speed on current developments so that we may find and utilize key advantages of the law.

We mark and utilize every benefit afforded to business owners as it relates to the Internal Revenue Code. We stand by that commitment to our clients.

Disclaimer: Material contained in this website is intended for informational purposes only and should not be interpreted as legal advice. The content does not constitute an attorney-client relationship between the user and Law Offices of Christy Lee, P.C., and users should not act on the content without seeking legal counsel in their own jurisdictions.