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Internal Revenue Code – Criminal Investigations

August 30, 2017


Texas IRS Tax Attorney Serving Clients Nationwide

A criminal tax prosecution begins only after a lengthy thorough investigation by the IRS into the taxpayer’s allegedly illegal conduct. At Brown, PC, we believe that the key to preserving your freedom and reputation is to involve us as soon as you are notified that the investigation underway. We have succeeded in heading off investigations, preventing charges from being filed and saving clients the time, money and reputational damage that may be associated with criminal tax prosecutions.

Where Does the IRS Find Cases?

The Criminal Investigations Division (CID) is the law enforcement arm of the IRS. It becomes aware of potential criminal conduct as a result of civil audits or through the report of a collections officer. It is also possible for CID to receive information from the public or from investigations already being performed by law enforcement authorities at the federal or state levels.

The Investigation

Once an investigation opens, the IRS, on many occasions, sends notice to the target. The agency will also subpoena bank records, conduct surveillance and interview witnesses to get more information. Our Texas-based IRS defense attorneys have succeeded in having many cases thrown out at this stage. Because the investigation may take up to two years, this is the best time for us to create strategies to defeat the charges before they ever get off the ground. This is why it is critical to involve our firm early in your case.

After the Investigation

When the IRS Special Agent is finished with the investigation, he or she will recommend that the case be prosecuted because there is enough evidence to go forward or will instead recommend that the case be dropped. Assuming that the case goes forward, there are two opportunities for the taxpayer to have the case reviewed. At either stage, your attorney can urge the government not to file charges. The two stages of review are:

  • IRS Attorney/Special Agent in Charge review
  • U.S. Department of Justice Tax Division review

At either stage, we may be able to show the IRS that the evidence does not actually support criminal charges and therefore the case should be thrown out.

Why Brown, PC?

Trends in IRS investigations show that once the IRS decides to prosecute, it pursues convictions aggressively and has been very successful in obtaining them. Brown, PC is home to many attorneys and IRS Enrolled Agents who have direct experience working for or with the IRS. That experience sets us apart from firms that only dabble in tax defense as part of a criminal defense practice.

Contact a Texas Internal Revenue Code Defense Lawyer

If you are under investigation by the IRS for any potential tax-related crime or non-tax financial crime, call Brown, PC immediately. Schedule your free consultation by calling 888-870-0025 or by contacting our Fort Worth law office online. We represent individuals and business entities throughout the United States.