Tax Fraud Lawyers Who Know How the IRS Thinks

Facing IRS criminal investigation or tax fraud charges?

We understand exactly how federal prosecutors and IRS agents build tax crime cases. We use that knowledge to tear those cases apart. We handle tax evasion charges, false return allegations, and IRS Criminal Investigation cases.

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Work With The Best Federal Tax Fraud Lawyers

Federal tax crimes come with serious consequences. You could face years in federal prison. Fines can reach hundreds of thousands of dollars. A felony conviction stays on your record forever.

Here’s what makes this worse: The IRS Criminal Investigation Division wins 90% of the cases they bring to trial. By the time they charge someone, they’ve already spent months or years building their case.

If you’re under investigation or facing charges, you need lawyers who have seen this from the inside. We have.

Our Role as Your Tax Evasion Lawyer

Stop investigations before charges are filed: We step in during the IRS CI phase and present evidence that may convince the Department of Justice to drop the case entirely.
Guard your constitutional rights: IRS agents sometimes push boundaries during interviews and searches. We make sure they follow Fourth and Fifth Amendment rules.
Challenge the "willfulness" requirement: The government must prove you broke the law on purpose. We build a record that raises real doubt about whether you knew your actions were illegal.

What Counts as Tax Fraud?

Tax fraud means lying to the IRS on purpose to avoid taxes you owe. This includes hiding income, making up deductions, keeping money in secret accounts, or filing returns you know are wrong.

The key word is purpose. Honest mistakes are not fraud. To convict you of a crime, prosecutors must prove you knew what you were doing was illegal and did it anyway.

Tax fraud can lead to civil penalties (up to 75% of what you owe) or criminal charges (up to 5 years in prison). The difference between a sloppy error and a crime often comes down to one question: Did you mean to do it?

That distinction could mean the difference between writing a check and going to prison.

Federal Tax Crimes We Defend

Our tax fraud attorneys defend individuals and businesses against the full spectrum of federal tax crimes:

Tax Evasion (26 U.S.C. § 7201)

The government’s most serious charge. They must prove you had unpaid taxes, took action to hide it, and did so on purpose. We challenge all three elements.

Penalty: Up to 5 years in prison and $100,000 in fines ($500,000 for corporations)

Filing False Tax Returns (26 U.S.C. § 7206)

Claiming deductions you didn’t earn. Leaving income off your return. Submitting fake documents. If the IRS says you lied on paper, we defend you.

Penalty: Up to 3 years in prison and $100,000 in fines

Failure to File Tax Returns (26 U.S.C. § 7203)

A misdemeanor on its own, but prosecutors often stack it with other charges to increase pressure. We work to keep charges from piling up.

Penalty: Up to 1 year in prison per unfiled year and $25,000 in fines

Employment Tax Fraud

Business owners who miss payroll tax obligations face personal liability. The IRS can come after your personal assets, not just the company’s.

Penalty: Civil trust fund penalties plus criminal prosecution

Conspiracy to Defraud the IRS (18 U.S.C. § 371)

Prosecutors use conspiracy counts to drag in multiple defendants and increase leverage. We fight to get clients removed from group indictments.

Penalty: Up to 5 years in prison

Money Laundering (18 U.S.C. § 1956)

When the government claims you hid where money came from, prison exposure jumps dramatically. This charge changes everything.

Penalty: Up to 20 years in prison

FBAR and Offshore Account Violations

Unreported foreign accounts trigger criminal penalties plus civil fines that can exceed your entire account balance.

Penalty: Up to 5 years in prison and $250,000 in fines

Get Help With Offshore Tax Issues

Don't Face the IRS Alone.

Federal tax crimes carry years in prison and permanent felony records. Our criminal tax defense attorneys have helped clients avoid prosecution, reduce charges, and stay out of prison. Contact us before your situation gets worse.

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Types of Tax Fraud Under Federal Law

Federal tax fraud under 26 U.S.C. § 7206 covers different ways people cheat on their taxes. Every violation requires proof that you acted on purpose. You must have known what you were doing was wrong. Here are the main types of fraud the government goes after when taxes are owed.

Filing False Returns

Signing a tax return with false information is a federal crime when you know the numbers are wrong. This goes beyond math errors or missed deductions. It means lying about income, inventing expenses, or claiming credits you know you don’t qualify for. And you signed the return under penalty of perjury saying it was accurate.

Preparing or Helping Prepare Fraudulent Returns

You don’t have to file the return yourself to face charges. If you help prepare a tax document knowing it contains lies, you’re on the hook. Accountants, tax preparers, and even friends who help with fraudulent filings can be prosecuted. It doesn’t matter if the person who filed knew the return was false.

Creating False Documents

Making fake records to back up a fraudulent tax position is its own crime. This includes forging receipts, creating fake invoices, altering business records, or producing counterfeit tax forms. The IRS sees document fabrication as strong proof you meant to break the law.

Hiding Assets from the IRS

Moving or concealing assets to stop the IRS from collecting what you owe is fraud. This includes hiding cash, sending money to offshore accounts, transferring property to family members, or using shell companies to hide ownership. The goal is keeping assets out of IRS reach.

Lying During IRS Negotiations

Making false statements or hiding information during audits, settlements, or offer in compromise talks is fraud. If you lie about your finances to get a lower settlement or deceive IRS agents during an examination, you face criminal charges on top of your original tax problem.

The Willfulness Requirement

Every tax fraud charge requires the government to prove you acted on purpose. They must show you knew your actions broke the law and did it anyway. Evidence can be direct (emails about hiding income) or circumstantial (a pattern of underreporting over several years). Without clear proof you meant to cheat, there is no criminal case. This is where we focus our defense.

How We Defend Against Tax Fraud Charges

The government’s case isn’t always as strong as it looks. We find the weaknesses and use them. When evidence against you is solid, we negotiate. Pre-indictment talks with the Department of Justice can lead to dropped charges, reduced charges, or plea agreements with far less prison time.

Challenging Willfulness

If you truly believed your conduct was legal, you cannot be convicted. Even if that belief was unreasonable. We dig into what you actually knew, what you believed, and what advice you received. The government must prove beyond a reasonable doubt that you knew you were breaking the law. Doubt is our weapon.

Professional Advice

Did you rely on your accountant or tax attorney? If you gave them accurate information and followed their guidance in good faith, that can destroy the willfulness element. Your accountant may have made the mistake. But if you trusted them honestly, you shouldn’t go to prison for it.

Insufficient Evidence

The government must prove every element beyond a reasonable doubt. We pick apart their evidence looking for weaknesses, inconsistencies, and gaps. Tax math is complicated. The government’s numbers aren’t always right. We bring in forensic accountants to challenge their calculations and expose their errors.

No Tax Deficiency

Tax evasion requires proof you actually owed more than you paid. If unclaimed deductions, credits, or losses offset the income they say you hid, there may be no deficiency. No deficiency means no crime.

Statute of Limitations

Tax evasion has a 6-year statute of limitations. Failure to file has a 6-year limit from the date the return was due. If charges fall outside these windows, we move to dismiss.

Constitutional Violations

Evidence obtained through illegal searches can be thrown out. Coerced statements can be suppressed. We examine whether IRS agents violated your Fourth or Fifth Amendment rights during the investigation. Bad evidence doesn’t get to be used against you.

Warning Signs You May Be Under Criminal Tax Investigation

Most people don’t know the IRS is investigating them until it’s too late. By then, agents have been building a case for months. Sometimes years. Spotting the warning signs early gives you time to prepare a defense before charges are filed.

Direct Contact from IRS Criminal Investigation

IRS Criminal Investigation (IRS CI) special agents carry badges. They are not the same as revenue agents who handle civil audits. CI agents investigate crimes. If a CI special agent contacts you, your family, your business partners, or your accountant, this is serious. Do not talk to them without a lawyer present. Everything you say can be used against you in court.

Your Civil Audit Suddenly Stops

You’re in the middle of an audit. Then the revenue agent stops calling. They stop requesting documents. They cancel meetings without explanation. This silence may mean your case has been sent to Criminal Investigation. Civil audits that find signs of fraud get referred for criminal review.

Third-Party Contacts

IRS CI agents often talk to witnesses before they ever contact you. If you hear that investigators reached out to your bank, employer, accountant, business partners, or family members, you may already be a target.

Grand Jury Subpoena

A federal grand jury subpoena for documents or testimony is a clear sign of criminal investigation. Grand juries decide whether to file criminal charges. If you receive one, call a criminal tax defense attorney immediately. Do not try to respond on your own.

Bank Account Activity

Frozen funds. Declined transactions. Notices that your records have been subpoenaed. These are red flags. Banks file Suspicious Activity Reports (SARs) that can trigger criminal investigations.

Letter from DOJ Tax Division

If you get a letter from the Department of Justice Tax Division, charges may be coming soon. The DOJ Tax Division prosecutes federal tax crimes. A letter from them means your case has moved past investigation into active prosecution.

What To Do If You See Warning Signs of Tax Fraud Investigation

Do not discuss your tax situation with anyone except a criminal defense attorney.

Do not destroy documents. Obstruction charges are often easier to prove than the original tax crime.

Do not contact potential witnesses.

Do contact a tax fraud defense attorney immediately.

The attorney-client privilege protects what you tell your lawyer. Your accountant and tax preparer don’t have this protection. They can be forced to testify against you.

Federal Tax Crime Penalties

Federal tax crimes carry penalties that can change your life forever. Knowing what you’re up against helps you make smart decisions about your defense.

Crime	Maximum Prison	Maximum Fine (Individual)	Maximum Fine (Corporation)
Tax Evasion (§ 7201)	5 years	$100,000	$500,000
Filing False Returns (§ 7206)	3 years	$100,000	$500,000
Failure to File (§ 7203)	1 year per count	$25,000	$100,000
Conspiracy (18 U.S.C. § 371)	5 years	$250,000	$500,000
Money Laundering (§ 1956)	20 years	$500,000	$500,000
FBAR Violations (willful)	5 years	$250,000	N/A

Frequently Asked Questions About Tax Fraud Defense

What should I do if IRS Criminal Investigation contacts me?

Do not talk to IRS CI special agents without a lawyer. You have the right to remain silent and the right to an attorney. Politely refuse to answer questions. Do not lie, because false statements to federal agents is its own crime. Do not agree to searches. Call a criminal tax defense attorney right away. Attorney-client privilege protects everything you tell your lawyer.

What is the difference between tax fraud and tax evasion?

Tax evasion is a specific crime under 26 U.S.C. § 7201. It requires three things: unpaid taxes, an act to hide them, and intent. Tax fraud is a broader term that covers several crimes, including filing false returns, failing to file, and employment tax violations. All tax crimes require proof that you broke the law on purpose, not by accident.

Can I go to prison for tax fraud?

Yes. Tax evasion carries up to 5 years in federal prison per count. Filing false returns carries up to 3 years per count. Money laundering can add up to 20 years. IRS Criminal Investigation wins about 90% of the cases they prosecute. Most people convicted serve prison time. There is no parole in the federal system. You serve at least 85% of your sentence.

What is "willfulness" in tax fraud cases?

Willfulness is the most important element in any tax crime case. The Supreme Court defines it as a “voluntary, intentional violation of a known legal duty.” The government must prove you knew your actions were illegal and did them anyway. Honest mistakes and good-faith misunderstandings are valid defenses. If you truly didn’t know your conduct was illegal, you cannot be convicted.

Can making an honest mistake on my tax return result in criminal charges?

Usually no. Criminal tax charges require intent. Honest mistakes typically result in civil penalties: additional taxes, interest, and accuracy penalties. Not prison. However, a pattern of errors, large dollar amounts, and other “badges of fraud” can make mistakes look intentional to investigators. If you’re worried about past returns, talk to a criminal tax attorney before the IRS contacts you.

What are "badges of fraud"?

Badges of fraud are behaviors that suggest intentional cheating rather than honest mistakes. The IRS uses these patterns to decide which cases deserve criminal investigation:

-Maintaining two sets of books or destroying records
-Making false statements or filing false documents
-Hiding income in offshore accounts
-Using cash to avoid paper trails
-Substantial understatement of income over multiple years
-Failure to cooperate with auditors

The more badges present, the stronger the government’s case against you.

How long does a tax fraud investigation take?

IRS CI investigations usually take 1 to 3 years before charges are filed. Complex cases take longer. The process includes gathering evidence, interviewing witnesses, analyzing finances, and internal IRS review. Cases that survive review go to the DOJ for a prosecution decision. From investigation to indictment can take 2 to 5 years. This timeline creates opportunities for early defense intervention.

What is the IRS Voluntary Disclosure Program?

The Voluntary Disclosure Program lets taxpayers come forward about past tax problems before the IRS finds out. Successful disclosure usually means civil penalties instead of criminal charges. The rules are strict: you must act before the IRS starts investigating, disclose everything, and cooperate fully. If you’re already under investigation, this option is closed. Talk to a criminal tax attorney to find out if you qualify.

What is the difference between civil and criminal tax cases?

Civil cases are about money. Criminal cases are about prison. Civil tax cases involve disputes over what you owe and end with financial penalties. Criminal cases involve accusations of intentional law-breaking and can end with incarceration. The IRS handles most issues civilly through audits and collection. Criminal cases go to IRS Criminal Investigation and the Department of Justice. Civil cases use a lower “preponderance of evidence” standard. Criminal cases require proof “beyond a reasonable doubt.”

How much does criminal tax defense cost?

But you’re facing prison time, a felony record, and financial penalties that could dwarf attorney fees. Costs depend on how complex your case is and whether it goes to trial. We discuss fees openly during your first consultation. Consider what’s at stake: years behind bars, a permanent criminal record, and fines that can exceed defense costs many times over.

Protect Your Freedom. Contact a Tax Fraud Defense Attorney Now.

If IRS Criminal Investigation has contacted you, if you’ve received a grand jury subpoena, or if you’re facing tax fraud charges, every day matters.

The government is building their case while you wait. Evidence is being gathered. Witnesses are being interviewed. Decisions about your future are being made without you in the room.

Your consultation is confidential and protected by attorney-client privilege. Unlike conversations with your accountant, what you tell us stays between us. We’ll look at your situation honestly and tell you exactly what you’re facing and what we can do about it.

Don’t wait until you’re indicted. Don’t try to talk your way out of this alone. Don’t assume it will disappear.

The consultation is free. Your freedom is not.