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Understanding and Resolving IRS Criminal Matters

The Internal Revenue Service has its own law enforcement unit, known as the Criminal Investigation Division (CI). CI is a powerful force within the IRS, charged with the task of investigating potential criminal violations of the Internal Revenue Code and any financial crimes related to taxation.

The IRS Agents who work in the Criminal Investigation Division have tremendous legal and technical expertise, and are backed by the resources of the IRS. Therefore, if you are the target of an IRS criminal investigation, it is imperative that you consult a tax law firm capable of taking on these extremely challenging cases.

Brown, PC is that kind of law firm. We are led by founding attorney Lawrence Brown, a former trial attorney with the Tax Division of the Department of Justice. Our associate attorneys all have extensive experience in criminal tax matters, and we employ four IRS Enrolled Agents – retired IRS agents with more than 100 years of collective experience working within the IRS itself. We are one of the few firms in the country capable of matching or exceeding the skill level of the IRS’ attorneys and law enforcement personnel.

What Crimes Does the IRS Criminal Investigation Division Handle?

CI deals with four types of crimes:

  • Legal source tax crimes: This is the category into which most tax crimes fall. It includes cases involving the Questionable Refund Program, tax return preparers and failure to file tax returns. It also encompasses employment tax and excise tax crimes.
  • Illegal source financial crimes: This type of crime includes gambling, money laundering and other financial crimes that are not directly tax crimes but that result in untaxed dollars making their way into the hands of accused criminals.
  • Narcotics-related financial crimes: Because the drug trade involves billions of dollars that escape taxation, the IRS seeks to root out drug activity by prosecuting trafficking, tax evasion fraud and other crimes that revolve around drugs and the money they generate.
  • Counterterrorism financing: The IRS is involved in uncovering the money trail that may be left by those planning terrorist attacks in the U.S. and abroad.

Dealing With IRS Law Enforcers

The strength of Brown, PC is that we are first and foremost a skilled group of criminal tax defense lawyers. We regularly perform our own investigations and interface with the IRS and United States Department of Justice in criminal matters involving our clients. We encourage you to reach out to us for help as soon as you get notice of the investigation. Typically, the IRS takes one to three years to put together its case. During that time, we can work to avoid charges altogether and build a defense strategy. Moreover, we can get to work on ways to preserve your professional reputation and good name.

You should not and do not have to deal with the law enforcement arm of the IRS on your own. Let the experienced tax law professionals at Brown, PC protect your rights, freedom and reputation.

Defending Against an IRS CI Investigation

While IRS audits and IRS CI investigations may involve similar subject matter, IRS CI investigations present different risks—and therefore require a different approach. Handling these investigations is a niche practice area, so choosing the right defense firm is critical.

At Brown, PC, a significant portion of our practice is devoted to representing clients in IRS CI investigations. Each Texas IRS criminal investigation lawyer at our firm has substantial experience representing clients in IRS CI matters, and we have a long record of success protecting our clients against serious federal criminal charges. This includes protecting our clients from facing charges for:

  • Aiding and abetting
  • Attempt and conspiracy
  • Making false statements to IRS revenue agents or IRS CI investigators
  • Tax evasion
  • Tax fraud
  • Offshore disclosure violations
  • Wire fraud, money laundering, identity theft and other white-collar federal crimes

While IRS CI is the criminal enforcement arm of the IRS, its authority is not restricted to investigating tax-related crimes. IRS CI investigates a broad range of other crimes as well in both tax-related and non-tax-related cases.

Special Agents at IRS CI frequently work alongside their counterparts at the Federal Bureau of Investigation (FBI), U.S. Department of Justice (DOJ), and other federal law enforcement agencies as well; and, in many cases, targeted individuals and companies will be facing scrutiny from multiple angles. We have the experience and capabilities required to handle these large-scale investigations effectively, and we limit our practice to representing select high-income and high-net-worth clients in cases involving significant exposure.

Submitting a Voluntary Disclosure to IRS CI

In addition to representing clients in high-stakes IRS CI investigations, we also work with individuals and companies to help them avoid these investigations when possible. If you have concerns about facing scrutiny from IRS CI but are not currently the target of a federal investigation, you may be able to avoid an investigation by submitting a voluntary disclosure.

As IRS CI explains, “[a] voluntary disclosure occurs when you provide a truthful, timely, and complete disclosure . . . through designated procedures;” and, when a taxpayer makes a voluntary disclosure, this “may result in prosecution not being recommended.” However, non-prosecution is not guaranteed, and voluntarily disclosing a violation of federal law can be extremely risky. As a result, an informed and strategic approach is required.

Despite the risks involved, submitting a voluntary disclosure will be taxpayers’ best option in some cases. If you believe that you (or your company) may be at risk of facing an IRS CI investigation, we can help you decide whether voluntary disclosure is the right option. If it is, we can prepare the disclosure and work proactively with IRS CI on your behalf to facilitate a favorable resolution that avoids the possibility of a grand jury indictment.

Understanding the Potential Consequences of a Federal Criminal Investigation

Whether you are facing scrutiny from IRS CI or you are considering a voluntary disclosure, it is important to understand the potential consequences of a federal criminal investigation. While IRS audits can trigger significant financial liability, the consequences of criminal prosecution can be far greater. Along with financial penalties, criminal charges can also lead to federal imprisonment. Most criminal violations of the Internal Revenue Code carry a maximum sentence of one to five years of prison time. However, crimes such as wire fraud and money laundering can carry 20 to 30 years behind bars.

We Help Our Clients Avoid These Consequences

Regardless of the penalties you may be facing, we can use our experience to help you avoid unnecessary consequences. In IRS CI matters, our representation typically involves:

  • Prompt Case Assessment and Intervention (if Necessary) – Our attorneys will begin by thoroughly assessing the facts of your case; and, if you are facing a pending investigation, we will intervene promptly to protect you.
  • Strategic Counseling and Defense – We will counsel you throughout the process while formulating and executing a comprehensive, cohesive and custom-tailored defense strategy.
  • Communication with IRS CI – Whether you are under investigation or need to submit a voluntary disclosure, we will communicate with IRS CI on your behalf, working to maintain a constructive dialogue that facilitates a favorable outcome.
  • Assistance with Subpoenas, Search Warrants and Disclosures – If you receive a subpoena or search warrant, we will explain everything you need to know. If it makes sense to submit a voluntary disclosure, we will guide you through the process.
  • Targeting a Favorable Pre-Charge Resolution – Ultimately, our representation will be focused on helping you obtain a favorable resolution that avoids federal criminal charges and the risks (and publicity) that come with them. 

Contact a Dallas-Fort Worth Criminal Tax Defense Attorney

If you have been targeted by an IRS criminal investigation, call Brown, PC immediately at 888-870-0025 or contact our Texas IRS disputes law firm online. We will intervene forcefully and intelligently. From our Forth Worth office, we represent clients throughout Texas and across the United States.