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Entrepreneur Targeted by IRS Criminal Investigation for Tax Evasion, Money Laundering, and Structuring of Monetary Transactions Sentenced to Probation


Our client was a female entrepreneur who was celebrated in her city’s business community for her enormous success in a male-dominated industry. When her company’s pattern of cash deposits prompted her bank to submit a Suspicions Activity Report to the Department of Treasury, she was targeted by IRS criminal investigators for a variety of violations including tax evasion, money laundering, structuring of monetary transactions, and conspiracy.


We engaged forensic accountants and a former IRS special agent under the attorney-client privilege, audited our client’s tax returns, and analyzed her business and personal financial transactions. We shared our findings with the IRS Special Agents investigating the case and we persuaded them that there had been no tax evasion, money laundering, or structuring of monetary transactions.

During the course of our respective investigations, however, it became clear to our team and the IRS Special Agents that our client had willfully failed to file hundreds of Forms 8300 with the Treasury Department for a cash transaction in excess of $10,000. Each failure to file constituted a separate criminal offense carrying up to five years in federal prison.

Because we had no viable defense, our client entered into a plea agreement which called for her to plead guilty to a single count of willful failure to file a Form 8300 and provided that the government would bring no other charges against her. In response to a presentence report that recommended a guideline imprisonment range of 30-37 months, we filed a motion for downward variance outlining our client’s exemplary citizenship and outstanding contributions to her community and requesting a sentence of probation.


Our client was sentenced to one year of probation.