June 26, 2018
Criminal Tax Case Against Texas Board-Certified Attorney Dismissed:
We were hired during the late stages of a criminal tax investigation targeting an attorney certified in real estate law by the Texas Board of Legal Specialization. By the time we were hired, the IRS had completed its investigation and had recommended to the U.S. Department of Justice Tax Division that our client be charged with three counts of tax evasion and one count of money laundering.
We assembled a team that included a financial investigator (former IRS Criminal Investigation Division Special Agent) and a CPA who specialized in accounting procedures for professional practices and aggressively investigated the case. Over a three month period, the professionals involved in defending the client turned away a number of other potential clients in order to devote their time and effort to the client’s case, as the IRS and Department of Justice had been working on the case for a number of years.
Diligence paid off and the team identified a number of significant weaknesses in the government’s case, including witness credibility issues and alternative interpretations with regard to tax calculations. The team made presentations before trial attorneys and section chiefs at the Department of Justice Tax Division in Washington, D.C., and the United States Attorney’s Office in Dallas, and ultimately convinced government attorneys to dismiss the case.
Criminal Tax Case Against Business Owner Dismissed:
We were hired by an entrepreneur, with business holdings in the automobile and real estate industries, who was the target of an IRS criminal investigation. We assembled a team that included industry experts and former IRS special agents, and conducted a parallel investigation, which identified a number of problems with the government’s case.
The team made skillful presentations to IRS attorneys and attorneys at the Department of Justice Tax Division, and convinced government attorneys to dismiss the case.
Felony Tax Evasion Charges Against CPA Dismissed:
We were hired by a Certified Public Accountant after the IRS had completed a multi-year investigation and recommended to the Department of Justice Tax Division that he be charged with three felony counts of tax evasion. We assembled the appropriate team, and after diligent investigation determined that the defense case had a number of significant weaknesses and that it would not be in the client’s best interest to proceed to trial.
The defense team engaged in skillful negotiation with the Department of Justice Tax Division and the local U.S. attorney’s office, and convinced the government attorneys to dismiss the felony tax evasion counts. Pursuant to a plea agreement, the client pled guilty to one misdemeanor count of failure to file an income tax return, and as part of a global agreement remained eligible to retain his CPA license.
Tax Consulting Company And Founders Targeted In Mail Fraud/Wire Fraud Investigation — Prosecution Declined:
A tax consulting company and its founders were the targets of a federal criminal investigation and faced multiple mail fraud, wire fraud, money laundering and conspiracy counts related to sophisticated state tax minimization strategies that the company implemented on behalf of client companies throughout the United States.
With the help of carefully chosen consulting experts, we conducted a detailed analysis of each of the strategies implemented by our clients. Following the review and analysis of the tax minimization strategies at issue, our experts determined that each strategy, although complex and aggressive, was consistent with a reasonable interpretation of current tax law and authority.
We made a number of presentations to prosecutors and agents and ultimately persuaded the government to decline prosecution.