Navigating Tax Controversies with Strategic Wisdom and Integrity
We are a law firm focusing exclusively on resolving a broad range of civil and criminal tax matters with the Internal Revenue Service (the "IRS") and state taxing authorities. We represent clients across the United States and around the world who are facing serious tax issues. Our team of tax attorneys is committed to providing honest legal counsel to taxpayers facing difficult circumstances.
We are a law firm focused on tax controversy, white collar criminal defense, and estate planning.
Nashville Tax Fraud Attorneys
Our team of criminal tax defense attorneys helps taxpayers in all phases of the criminal tax process, from criminal tax prosecutions and criminal tax investigations to civil tax matters involving potential criminal exposure. Led by criminal tax defense attorneys who are also licensed CPAs, we use our combination of tax litigation and criminal defense experience to deliver comprehensive legal representation to address the unique nature of criminal tax cases.
Criminal tax investigations are often caused when an agent or revenue officer with the Internal Revenue Service (the “IRS”) identifies potential criminal tax fraud and submits a referral to the IRS criminal investigation division (i.e., IRS tax audits involving cryptocurrency, abusive tax shelter transactions, or other alleged tax violations). Criminal tax investigations are also caused when third parties report potential criminal tax fraud to the IRS, Department of Justice, or U.S. Attorney’s Office.
The sole purpose of a criminal tax investigation is to determine whether criminal tax charges should be brought against a taxpayer. Criminal tax investigations are generally characterized as administrative investigations or grand jury investigations. Administrative criminal tax investigations are led by the IRS Criminal Investigation Division (through IRS Special Agents) while grand jury investigations are typically jointly led by the Department of Justice Tax Division and the IRS criminal investigation division.
Criminal tax cases and investigations cover a broad range of tax issues, including federal income tax, employment tax, cryptocurrency, sales tax (with state taxing authorities), and foreign account disclosure (information reporting such as FBARs). Sometimes criminal tax cases and investigations are conducted alongside other white collar charges and/or investigations such as wire fraud and money laundering.
Effective legal representation in a criminal tax case requires specialized education, training, and experience in tax law, tax controversy, and criminal cases. We invite you to request a consultation with a criminal tax attorney to learn more about how we can help.
Frequently Asked Questions
+ What is the punishment for tax evasion?For tax evasion, you may face up to five years of jail time and be fined up to $100,000 ($500,000 for corporations).
+ What is the difference between a criminal tax lawyer and other defense lawyers?While some defense lawyers handle criminal tax cases, it is important to understand the differences when selecting a lawyer to represent you. Because of the highly technical and complex nature of the tax code, tax crimes are prosecuted and proved quite differently than other crimes. The lawyer you choose to represent you should be familiar with tax law and how the IRS investigative process works in addition to courtroom experience.
+ What is the difference between tax evasion and tax fraud?While the terms tax evasion and tax fraud are often used interchangeably, there are distinctions. Tax fraud is more broadly defined and can apply in both civil and criminal cases while tax evasion is more narrowly defined and only applies to criminal cases.
+ What are the qualifications to be a criminal tax attorney?There are no extra requirements or qualifications to be a criminal tax attorney. However, criminal tax attorneys generally are well-educated in tax law, have significant experience with criminal tax cases, and have credentials beyond their law degree (such as a CPA license).
Our firm is committed to delivering results for our clients. We invite you to review a sample of representative criminal tax matters we have resolved for our clients.
No Jail Time Imposed for Conviction Under 26 U.S.C. § 7206(2)
Represented accountant facing allegations of fraudulently preparing tax returns causing a tax loss of $2,329,255 to the government. Negotiated a plea agreement where accountant pled guilty for three felony counts of Filing, Aiding, or Assisting in Filing a False Tax Return under 26 U.S.C. § 7206(2) and the tax loss was limited to $37,125. At sentencing hearing, DeWitt Law argued for a downward departure from the guidelines sentence range of 10 to 16 months imprisonment. The Court granted the downward departure and imposed a sentence of probation with no jail time.
25 Felony Tax Evasion Charges Dismissed
Represented taxpayer facing 27 felony (and 1 misdemeanor) tax crimes. 25 felony charges and 1 misdemeanor charge dismissed. Plea agreement and pre-trial diversion granted to Taxpayer resulting in no jail time, supervised probation for 2 years, and no criminal record upon completion of diversion.
30 Felony Tax-Related Charges Dismissed
Taxpayer indicted for 31 tax-related felony counts. 30 charges were dismissed and case was resolved through pre-trial diversion with no jail time and expungement of criminal record upon completion of diversion.
No Charges Filed in IRS Criminal Investigation Against Attorney
Represented attorney in complex criminal investigation by the IRS Criminal Investigation department. Investigation closed after approximately 3 years with no criminal charges filed.
No Charges Filed in IRS Criminal Investigation Against Owner of Multi-State Corporation
Represented owner of corporation operating in multiple states in complex criminal investigation by the IRS Criminal Investigation department. Investigation closed with no criminal charges filed.
No Charges Filed in IRS Criminal Investigation
Represented taxpayer in criminal investigation by the IRS Criminal Investigation department. Investigation closed with no criminal charges filed.
IRS Criminal Investigation - No Criminal Charges Filed
Represented taxpayer investigated by the IRS Criminal Investigation department for potential tax crimes related to over $5 million dollars in unreported bank account deposits. Investigation closed and no criminal charges filed.
IRS Criminal Investigation - No Criminal Charges Filed
Represented taxpayer investigated by the IRS Criminal Investigation department for potential tax evasion through car dealership owned by Taxpayer. Investigation closed and no criminal charges filed. After the criminal investigation was closed, the IRS initiated a civil field audit for the same tax years. Represented Taxpayer in the civil audit, which resulted in $0 in additional tax.
IRS Fraud Investigation
Represented Taxpayer who owned a tax preparation company in a tax preparer fraud investigation. Investigation closed and no criminal charges filed or civil penalties, including fraud, assessed.
Federal Criminal Tax Issues/Charges
Criminal charges by the federal government include:
Tax Evasion - I.R.C. § 7201
Willful Failure to Collect or Pay Over Tax - I.R.C. § 7202
Failure to File, Supply Information or Pay Tax - I.R.C. § 7203
Fraudulent Withholding Exemption - I.R.C. § 7205
Fraud and False Statements - I.R.C. § 7206
Fraudulent Returns, Statements, or Other Documents - I.R.C. § 7207
Attempts to Interfere with Administration of Internal Revenue Laws - I.R.C. § 7212
Aiding & Abetting - 18 U.S.C. § 2
Conspiracy to Defraud the Government with Respect to Claims - 18 U.S.C. § 286
False, Fictitious, or Fraudulent Claims - 18 U.S.C. § 287
State Criminal Tax Charges
State can also charge with tax-related crimes. Examples of common state criminal tax-related charges include: