IRS Criminal Investigation Division: How It Works and What to Do If You’re a Target

The IRS Criminal Investigation Division is the only federal law enforcement agency with exclusive authority to investigate violations of the Internal Revenue Code. If you receive a visit from an IRS-CI special agent – or if you suspect one may be coming – this is not a billing dispute or a paperwork correction.

This is a federal criminal investigation, and everything you say from this point forward can be used against you.

Understanding what IRS-CI is, how it operates, and what happens at each stage of an investigation gives you the clearest possible picture of your situation.

It also gives you the foundation to make the right decision: calling a criminal tax defense attorney before you say a single word to any federal agent.

Key Insights: IRS Criminal Investigation Division

• IRS-CI is the only federal law enforcement agency with exclusive authority to investigate Internal Revenue Code violations – no other federal agency can charge you with a federal tax crime.
• The agency employs approximately 2,200 special agents operating from 18 U.S. field offices and 12 international posts, focusing on tax fraud, money laundering, narcotics proceeds, and cyber-financial crimes.
• IRS-CI maintains a federal conviction rate above 90% – one of the highest in all of federal law enforcement – because the agency prosecutes only cases it is confident it can win.
• In fiscal year 2024, IRS-CI opened 2,667 investigations, identified $9.1 billion in fraud, and reported 1,571 convictions. In fiscal year 2025, identified financial crimes rose to $10.59 billion.
• The most common investigation trigger is a civil audit that uncovers evidence of willful conduct – revenue agents are required to stop the audit and refer the case to IRS-CI when they find indicators of intentional fraud.
• Attorney-client privilege – available only through a licensed attorney, not a CPA or enrolled agent – protects your communications from the moment you engage counsel. Anything you tell a CPA can be subpoenaed.
• Voluntary disclosure is the most powerful tool available to taxpayers who have undisclosed income or offshore assets – but it is only available before IRS-CI opens an investigation.

What Is the IRS Criminal Investigation Division?

The IRS Criminal Investigation Division – officially designated IRS-CI – functions as the law enforcement arm of the Internal Revenue Service.

Founded in 1919 as the Intelligence Unit, IRS-CI gained national prominence in the 1930s for securing the conviction of Al Capone on income tax evasion charges when other agencies had failed to build a case.

That investigation established a template the division still follows: follow the money, document everything, and build cases that hold up at trial.

Today, IRS-CI operates with approximately 3,300 employees worldwide, including roughly 2,200 special agents.

Those agents work out of 18 field offices across the United States – from Atlanta and Boston to Phoenix and Seattle – plus 12 attaché posts abroad.

The current Chief of IRS-CI is Guy Ficco, who oversees an agency that now investigates not just tax fraud but narcotics trafficking, money laundering, public corruption, healthcare fraud, identity theft, and terrorism financing.

What makes IRS-CI unique among federal law enforcement agencies is jurisdictional exclusivity over the Internal Revenue Code.

The FBI can investigate bank fraud.

The DEA handles drug proceeds.

But only IRS-CI special agents have the authority to investigate criminal violations of Title 26 – the federal tax code.

When another federal agency is working a case involving tax-related financial crimes, they typically bring IRS-CI in as a partner.

How IRS-CI Differs From a Regular IRS Audit

Most IRS interactions are civil matters.

A revenue agent requests documentation. A CP2000 notice flags a discrepancy.

An examination asks you to substantiate deductions. These are serious, but they are administrative proceedings with administrative remedies.

IRS-CI investigations are criminal proceedings. The standard changes from “did you underpay your taxes” to “did you intentionally evade your tax obligations.” The distinction – willfulness – carries the difference between a penalty check and a federal indictment.

When IRS-CI gets involved, the agents working your case carry badges and firearms, have arrest authority, and are building a prosecutable case for the Department of Justice. A revenue agent examines your returns. An IRS-CI special agent is gathering evidence for a grand jury.

Factor	Civil IRS Audit	IRS Criminal Investigation
Who conducts it	Revenue agent (no arrest authority)	IRS-CI special agent (badge, firearm, arrest authority)
Standard applied	Did you underpay?	Did you intentionally evade?
Potential outcome	Additional tax + civil penalties + interest	Federal indictment, prosecution, prison time
Who can represent you	CPA, enrolled agent, or tax attorney	Licensed attorney only (privilege protection)
Communications protected?	No attorney-client privilege with CPA/EA	Attorney-client privilege required from day one
Can one become the other?	Yes – civil audit can trigger criminal referral	Criminal investigation rarely reverts to civil

There is one more critical difference. During a civil audit, your CPA can represent you. In an IRS-CI investigation, only a licensed attorney can provide protected communications through attorney-client privilege.

A CPA’s work product can be subpoenaed. Conversations with your tax attorney cannot.

How IRS-CI Is Organized and How Cases Get Assigned

IRS-CI operates through a structure that routes investigations from local field offices up through national leadership and, ultimately, to the Department of Justice for prosecution decisions.

At the field level, IRS-CI special agents work within one of 18 domestic field offices, each covering a defined geographic territory. Within each field office, agents are assigned to specific program areas based on the type of financial crime under investigation. The primary program areas include:

• Tax Fraud – underreported income, false deductions, employment tax fraud, and abusive return preparer schemes
• General Fraud – public corruption, healthcare fraud, identity theft, and COVID-related fraud (ERC schemes, PPP fraud)
• International Cases – offshore account concealment, FBAR violations, and cross-border financial crimes
• Narcotics and Organized Crime – money laundering from drug trafficking and criminal enterprises
• Cyber Crimes – cryptocurrency tax evasion, ransomware proceeds, and blockchain-related financial crimes

When a case opens, a supervisory special agent reviews the referral and assigns it to an available agent with relevant expertise. International cases involving offshore accounts typically go to agents with FBAR and foreign financial institution experience. Crypto cases increasingly go to agents trained in blockchain forensics.

The agent assigned to your case is a specialist – not a generalist – in the type of conduct under investigation.

What Triggers an IRS-CI Investigation

IRS-CI opened 2,667 investigations in fiscal year 2024 out of approximately 150 million individual returns filed. The agency is selective because it has limited resources and prosecutes only cases it expects to win. A 90% federal conviction rate – one of the highest in federal law enforcement – reflects that selectivity.

Investigations open through several channels:

Civil audit referrals. This is the most common pathway. A revenue agent conducting a civil examination encounters something that looks intentional rather than careless – double sets of books, fabricated invoices, bank deposits that exceed reported income by a factor of two or three.

At that point, the revenue agent is required to suspend the audit and refer the case to IRS-CI.

This referral is called an “eggshell audit” situation when it transitions from civil to criminal, and it represents the most dangerous moment for taxpayers who handled the audit without legal counsel.

Whistleblower complaints. Former employees, business partners, ex-spouses, and competitors all have the ability to file IRS Form 3949-A reporting suspected tax fraud.

Whistleblowers who provide information leading to collections of $2 million or more may qualify for financial awards under the IRS Whistleblower Program. This creates a financial incentive for people with inside knowledge to come forward.

Informant tips and law enforcement referrals. Other federal agencies – the FBI, DEA, Homeland Security Investigations – frequently work cases that generate financial evidence pointing to tax crimes. When an agent in one of those agencies sees indicators of tax fraud in a case they’re already working, the referral goes to IRS-CI.

Data analytics and artificial intelligence. The IRS Compliance Data Warehouse and AI-driven examination tools now flag statistical anomalies in returns at a scale that was impossible with manual review. Reported income significantly below lifestyle indicators, deduction patterns that fall outside statistical norms for a given industry, or cryptocurrency transaction data obtained from exchange records through John Doe summonses – all of these can generate automated flags that lead to human review and, eventually, investigation.

Third-party information returns. The IRS receives 1099s, W-2s, information from financial institutions, and foreign account data through FATCA reporting.

When what you reported on your return doesn’t match what your employer, bank, or foreign financial institution reported to the IRS, that discrepancy is visible in the system. Consistent gaps over multiple years are a primary investigation trigger.

Currency transaction reports and suspicious activity reports. Banks are required to file Currency Transaction Reports (CTRs) for cash transactions over $10,000 and Suspicious Activity Reports (SARs) for transactions that appear to be structured to avoid reporting thresholds.

IRS-CI has full access to the Financial Crimes Enforcement Network (FinCEN) database where these reports are stored. If you’ve been making cash deposits just under $10,000 – a practice called “structuring” – that pattern is visible and prosecutable independent of any underlying tax issue.

The IRS-CI Investigation Process: Stage by Stage

IRS-CI investigations follow a structured, multi-layered process designed to filter cases before committing prosecutorial resources. That filter works in both directions – it blocks weak cases from going forward, but it also ensures that cases that reach the prosecution stage have already survived multiple rounds of legal and factual review.

Stage 1: Subject Investigation

The investigation opens when a special agent receives a referral and a supervisory special agent approves opening a case. The subject of the investigation may have no idea this is happening. The initial phase focuses on gathering background financial data without direct contact – reviewing tax returns, obtaining bank records through summonses, reviewing currency transaction reports, and building a financial profile from publicly available and third-party sources.

Stage 2: Evidence Gathering

Once the preliminary picture suggests criminal conduct, the investigation moves into active evidence gathering. IRS-CI special agents have broad investigative authority and use a full range of law enforcement tools:

• Interviews – agents interview employers, business partners, accountants, employees, family members, and neighbors. These interviews are voluntary for third parties but can feel coercive. Every interview builds the factual record about your income, lifestyle, and financial behavior.
• Grand jury subpoenas – the government can use a grand jury to compel testimony and the production of documents. Our IRS tax fraud investigation defense page covers how we respond to these demands on your behalf. Bank records, brokerage statements, real estate records, and foreign account information can all be obtained through the grand jury process.
• Search warrants – when agents need to enter premises and seize records or electronic devices, they obtain search warrants. A search warrant served at your home or office means the investigation has advanced significantly.
• Financial analysis – IRS-CI special agents are trained as financial forensics specialists. They use net worth analysis, bank deposit analysis, and expenditure methods to reconstruct actual income even when formal records are incomplete or falsified. Agents are also trained to recover encrypted or deleted digital financial data.
• Surveillance – in some cases, especially those involving lifestyle discrepancies or undisclosed income sources, agents conduct physical surveillance to document spending patterns inconsistent with reported income.

If a special agent contacts you directly during this phase – by showing up at your home, calling your office, or requesting a meeting – your response to that contact is critically important. Federal law prohibits making false statements to federal agents. That means there is no safe conversation you can have with an IRS-CI special agent without an attorney present.

Stage 3: Special Agent Report

At the conclusion of the evidence-gathering phase, the investigating special agent prepares a Special Agent Report (SAR). The SAR is a detailed prosecution recommendation document – it presents all gathered evidence, explains the legal theory of the case, and provides a recommendation on whether to proceed with prosecution.

Per IRS Internal Revenue Manual Section 9.5.8, the SAR must logically present evidence supporting a criminal prosecution recommendation.

The SAR goes to a supervisory special agent for review. If approved, it moves to the IRS Office of Chief Counsel. Chief Counsel attorneys review the legal sufficiency of the case – essentially asking whether the evidence supports the charges and whether the legal theories hold up.

A case can be declined at this stage if Chief Counsel identifies significant legal weaknesses.

Stage 4: Department of Justice Review

Cases surviving Chief Counsel review are forwarded to the Department of Justice Tax Division (for tax-related charges) or the U.S. Attorney’s Office (for related financial crimes).

DOJ Tax Division attorneys review the case independently and make the final prosecution decision.

This is the stage where aggressive legal representation can still prevent prosecution. A criminal tax defense attorney with experience at this stage can present mitigating evidence, factual disputes, legal arguments, and information about the client’s circumstances directly to DOJ Tax Division attorneys. Cases have been declined for prosecution at this stage.

Once DOJ approves prosecution, the case moves to indictment and trial – options narrow dramatically.

Stage 5: Grand Jury and Indictment

If DOJ approves prosecution, a grand jury is convened. Grand juries hear evidence presented by the government and determine whether probable cause exists to indict. They do not hear defense arguments.

Indictment rates for cases presented to grand juries are extremely high.

After indictment, the case proceeds through the federal criminal court system toward trial or plea negotiation. At this stage, the goal shifts from preventing prosecution to achieving the best available outcome – reduced charges, a favorable plea agreement, or acquittal at trial.

What IRS-CI Special Agents Are Looking For

Special agents are not just looking for unpaid taxes. They are building a case for willful criminal conduct. The legal standard for most tax crimes requires the government to prove that you knew you had a legal obligation and deliberately chose to violate it.

This is called the willfulness element, and it is what separates a civil underpayment from a federal felony.

Evidence that agents specifically document includes:

• Income concealment – cash income not deposited to reported accounts, payments routed through nominees, offshore accounts with unreported balances
• False documentation – fabricated invoices, falsified business records, forged receipts submitted to reduce taxable income
• Lifestyle indicators – significant spending on real estate, vehicles, travel, and personal expenses inconsistent with reported income
• Prior knowledge indicators – prior audits, prior returns signed under penalty of perjury, communications about tax obligations that demonstrate awareness of requirements
• Concealment conduct – structuring cash transactions, using multiple nominee entities, moving funds offshore after receiving IRS correspondence

In fiscal year 2025, IRS-CI identified $10.59 billion in financial crimes and dedicated nearly 64% of investigative resources to tax-related offenses. The agency is not understaffed and is not slowing down.

Expanded AI tools and cryptocurrency tracing capabilities have made IRS-CI more effective at identifying patterns that would have been invisible to manual review a decade ago.

Common IRS Criminal Investigation Division Charges

IRS-CI investigations can result in charges under multiple federal statutes. The statute applied determines the penalties you face – and prosecutors regularly stack multiple charges across multiple years.

Charge	Statute	Max Prison	Key Element
Tax Evasion	26 U.S.C. § 7201	5 years per count	Willful attempt to evade any tax
Filing False Return	26 U.S.C. § 7206(1)	3 years per count	Willfully filing a return known to be false
Failure to File	26 U.S.C. § 7203	1 year (misdemeanor)	Willful failure to file; elevates with pattern
Money Laundering	18 U.S.C. § 1956	20 years per count	Concealing proceeds of tax fraud in transactions
Structuring	31 U.S.C. § 5324	5 years per count	Cash transactions structured to avoid CTR filing

Tax evasion is the most frequently charged offense. Under § 7201, fines reach $100,000 per count for individuals – or $250,000 under the Criminal Fine Enforcement Act. Prosecutors charge each tax year as a separate count, meaning three years of evasion can mean three stacked felonies.

Money laundering charges often accompany tax fraud when proceeds were moved through financial transactions to obscure their origin. At up to 20 years per count, money laundering exposure can exceed the tax evasion charge itself.

Willful FBAR violations in offshore concealment cases are typically charged alongside tax evasion. Civil penalties for willful FBAR violations can reach 50% of the highest account balance per year – on top of any criminal exposure.

How Silver Tax Group Defends Against IRS-CI Investigations

The most important thing to understand about defending an IRS-CI investigation is that the earlier legal counsel is retained, the more options remain available. By the time federal charges are filed, the best available outcomes have already narrowed significantly. The window where the outcome can be most favorably influenced is before the Special Agent Report reaches DOJ – and in some cases, before a referral to IRS-CI even occurs.

Attorney Chad Silver and the Silver Tax Group team bring specific capabilities to IRS-CI defense that most tax professionals cannot provide:

Attorney-client privilege from first contact. The moment you engage Silver Tax Group, your communications are protected by attorney-client privilege.

This is not a technicality – it is the legal shield that prevents the government from compelling your attorney to testify about your conversations and strategies. CPAs, enrolled agents, and tax resolution firms cannot provide this protection.

Early intervention before criminal referral. If a civil audit begins to show signs of criminal exposure – agents asking about intent, requests for communications rather than just financial documents, questions about why decisions were made – these are warning signs that a criminal referral may be forthcoming. An experienced criminal tax defense attorney can intervene at this stage, manage the civil audit’s scope, and sometimes prevent a criminal referral entirely through voluntary disclosure or corrected filings made through proper legal channels.

Voluntary Disclosure representation. The IRS Voluntary Disclosure Practice allows taxpayers to come forward before IRS-CI has initiated an investigation, resolving noncompliance through civil rather than criminal proceedings. Voluntary disclosure is a structured process with specific requirements, and its availability ends the moment IRS-CI opens a case on you.

Our attorneys have guided clients through voluntary disclosure for unreported offshore accounts, undisclosed cryptocurrency gains, and other sensitive compliance failures.

Investigation management and DOJ negotiation. Once an investigation is underway, our attorneys manage all communications with IRS-CI on your behalf, review evidence, and identify weaknesses in the government’s willfulness argument.

This direct engagement with prosecutors – before indictment – is where cases have been declined, where charges have been reduced, and where civil resolutions have been negotiated for conduct that would otherwise result in criminal prosecution. For a deeper look at defense strategy, see our detailed guide to when the IRS pursues criminal charges and how those decisions get made.

Trial-ready representation. Attorney Silver is admitted to the United States Tax Court and has the litigation experience to take cases to trial when that outcome serves the client’s interests.

Having counsel who can credibly threaten – and execute – trial changes negotiating dynamics with prosecutors. We have obtained plea agreements that avoided prison time, negotiated case dismissals at the DOJ review stage, and taken cases to trial with favorable outcomes.

Our attorneys have helped clients save over $100 million in IRS tax debts, and our approach to criminal defense reflects the same aggressive advocacy we bring to every IRS matter.

If you are under investigation or believe an investigation may be forthcoming, understand what your legal exposure actually looks like. Read our overview of criminal tax defense representation to understand what licensed attorneys can do that no other type of representative can provide.

Key Insights: IRS Criminal Investigation Division

• IRS-CI is the only federal law enforcement agency with exclusive authority to investigate Internal Revenue Code violations – no other federal agency can charge you with a federal tax crime.
• The agency employs approximately 2,200 special agents operating from 18 U.S. field offices and 12 international posts, focusing on tax fraud, money laundering, narcotics proceeds, and cyber-financial crimes.
• IRS-CI maintains a federal conviction rate above 90% – one of the highest in all of federal law enforcement – because the agency prosecutes only cases it is confident it can win.
• In fiscal year 2024, IRS-CI opened 2,667 investigations, identified $9.1 billion in fraud, and reported 1,571 convictions. In fiscal year 2025, identified financial crimes rose to $10.59 billion.
• The most common investigation trigger is a civil audit that uncovers evidence of willful conduct – revenue agents are required to stop the audit and refer the case to IRS-CI when they find indicators of intentional fraud.
• Attorney-client privilege – available only through a licensed attorney, not a CPA or enrolled agent – protects your communications from the moment you engage counsel. Anything you tell a CPA can be subpoenaed.
• Voluntary disclosure is the most powerful tool available to taxpayers who have undisclosed income or offshore assets – but it is only available before IRS-CI opens an investigation.

Frequently Asked Questions About the IRS Criminal Investigation Division

What is the IRS Criminal Investigation Division and what does it do?

The IRS Criminal Investigation Division (IRS-CI) is the law enforcement arm of the IRS. It is the only federal law enforcement agency with exclusive investigative jurisdiction over violations of the Internal Revenue Code. IRS-CI special agents investigate tax fraud, money laundering, narcotics-related financial crimes, public corruption, healthcare fraud, identity theft, and terrorism financing.

The agency employs approximately 2,200 special agents who work from 18 domestic field offices and 12 international attaché posts.

How do I know if I’m under IRS criminal investigation?

You may not know initially – early-stage IRS-CI investigations are conducted without notifying the subject. Warning signs include: an IRS-CI special agent contacting you directly or visiting your home or office; third parties (accountants, employees, business associates) reporting that they were contacted by an IRS agent asking questions about you; a civil audit where the examiner begins asking about your intent or decision-making rather than just requesting documentation; or receiving a target letter from the Department of Justice indicating you are the subject of a federal grand jury investigation. If any of these occur, contact a criminal tax defense attorney immediately and do not speak with any federal agent without counsel present.

What is the difference between a civil IRS audit and an IRS criminal investigation?

A civil audit is an administrative proceeding to determine whether you paid the correct amount of tax. The potential outcome is additional tax liability plus civil penalties and interest. An IRS-CI criminal investigation is a law enforcement proceeding aimed at determining whether you willfully violated federal law.

The potential outcome is federal indictment, prosecution, and prison time. Civil audits are conducted by revenue agents with no law enforcement authority. IRS-CI investigations are conducted by special agents who carry badges and firearms and have arrest authority.

The legal standard also differs: a civil audit establishes what you owed; a criminal investigation establishes whether you intentionally evaded what you owed.

What triggers an IRS criminal investigation?

The most common triggers are civil audit referrals (when a revenue agent finds evidence suggesting willful fraud), whistleblower complaints filed by former employees or associates, IRS data analytics identifying statistical anomalies in returns, third-party information mismatches between what you reported and what your bank or employer reported to the IRS, suspicious activity reports filed by financial institutions for structured cash transactions, and referrals from other federal agencies such as the FBI or DEA when their investigations reveal tax violations.

Can a civil IRS audit turn into a criminal investigation?

Yes, and this is one of the most dangerous aspects of any IRS audit. If a revenue agent discovers evidence of willful fraud during a civil examination – fabricated records, unreported accounts, deliberate income concealment – that agent is required to suspend the civil audit and refer the case to IRS-CI. Any statements you made, documents you provided, and information you disclosed during the civil audit can then be used as evidence in the criminal investigation.

This is why experienced criminal tax defense attorneys recommend legal representation from the very start of any audit that involves potential fraud exposure.

What crimes does IRS-CI prosecute most frequently?

• Tax evasion (26 U.S.C. § 7201) – willful attempt to evade any tax, carrying up to five years in prison and fines up to $100,000 per count. Prosecutors charge each tax year separately.
• Filing false returns (26 U.S.C. § 7206(1)) – willfully filing a return you know to be false. Carries up to three years in prison.
• Money laundering (18 U.S.C. § 1956) – using tax fraud proceeds to conceal their origin. Carries up to 20 years in prison.
• Structuring violations (31 U.S.C. § 5324) – making cash transactions to avoid currency reporting. Carries up to five years in prison.
• FBAR-related criminal referrals – willful concealment of offshore accounts, frequently charged alongside tax evasion in offshore cases.

What should I do if an IRS-CI special agent contacts me?

Do not speak with the agent, provide documents, or agree to a meeting without first retaining a criminal tax defense attorney. You are not required to speak with IRS-CI agents, and federal law makes it a crime to make false statements to federal agents – even casual conversation creates legal risk. Politely tell the agent you will have your attorney contact them.

Do not destroy, shred, or delete any documents, as document destruction after becoming aware of an investigation constitutes obstruction of justice. Call a criminal tax defense attorney as quickly as possible – attorney-client privilege protects everything you say to your attorney from that point forward.

What is voluntary disclosure and can it help me avoid criminal prosecution?

The IRS Voluntary Disclosure Practice is a program that allows taxpayers with undisclosed income, unfiled returns, or unreported offshore accounts to come forward proactively and resolve their noncompliance through a structured civil process rather than facing criminal prosecution. Voluntary disclosure is only available before IRS-CI has opened an investigation on you. Once the investigation begins, the program is no longer accessible.

Taxpayers who come forward through voluntary disclosure and satisfy its requirements generally receive civil penalties rather than criminal prosecution. Given the complexity and legal requirements of voluntary disclosure, it must be handled through experienced criminal tax defense counsel.

How long does an IRS criminal investigation take?

The timeline varies significantly depending on the complexity of the case, the number of years under investigation, whether international financial activity is involved, and how quickly the DOJ review process proceeds. Clear cases may conclude in 12 to 18 months. Complex multi-year investigations involving offshore accounts, multiple entities, or cooperation with foreign governments can take three to five years from investigation opening to final resolution.

The early phases of an investigation – before the subject is aware – can span many months before any direct contact occurs.

Does IRS-CI always result in criminal charges?

No. IRS-CI investigations pass through multiple review stages – supervisory special agent review, IRS Chief Counsel review, and DOJ Tax Division review – before charges are filed. Cases can be declined at any of these stages if the evidence is insufficient, legal theories don’t hold up, or mitigating circumstances are presented effectively.

An experienced criminal tax defense attorney can engage at the DOJ review stage specifically to present arguments for declining prosecution. That said, by the time a case reaches a grand jury, indictment rates are extremely high – early intervention is critical.

Sources

• IRS Criminal Investigation – About Criminal Investigation: https://www.irs.gov/compliance/criminal-investigation/about-criminal-investigation
• IRS Criminal Investigation – CI at a Glance: https://www.irs.gov/about-irs/criminal-investigation-ci-at-a-glance
• IRS Criminal Investigation Wikipedia Overview: https://en.wikipedia.org/wiki/IRS_Criminal_Investigation
• TIGTA – Criminal Investigation Trends FY2019-FY2023: https://www.tigta.gov/sites/default/files/reports/2025-08/20253S0028fr.pdf
• IRS Internal Revenue Manual – Investigative Reports (Section 9.5.8): https://www.irs.gov/irm/part9/irm_09-005-008
• 26 U.S.C. § 7201 – Tax Evasion: https://www.law.cornell.edu/uscode/text/26/7201
• 26 U.S.C. § 7206 – Filing False Returns: https://www.law.cornell.edu/uscode/text/26/7206

Facing an IRS-CI Investigation? Call Silver Tax Group Now.

If an IRS-CI special agent has contacted you, if you received a target letter, or if you suspect an investigation may be underway, the time to act is now – not after the next agent visit. Attorney Chad Silver and the Silver Tax Group team have defended clients through every stage of the IRS-CI process, from pre-referral voluntary disclosure through DOJ negotiation and federal trial. We have helped clients save over $100 million in IRS tax debts, and our attorneys are admitted to the United States Tax Court.

The first conversation is protected by attorney-client privilege and costs you nothing. Call (855) 900-1040 or complete our confidential case evaluation form to speak with a criminal tax defense attorney today.