Criminal Proceedings

A criminal tax case can arise in a variety of different ways but once it is initiated it is generally led either by a Special Agent from the IRS’s Criminal Investigation Division (“IRS-CI”) working alone, or by a federal prosecutor through the use of a grand jury with the assistance of an IRS-CI Special Agent. If there is enough evidence, the investigation will usually conclude with the issuance of an indictment or other charging document in which the United States government officially seeks to convict a taxpayer of one or more crimes.

Followed to its conclusion, a criminal case will require navigation through a series of issues, such as a taxpayer’s status as a witness, subject, or target, whether to make a proffer, plea negotiations, pre-trial issues, trial, sentencing and appeals. With a conviction rate in excess of 93 percent in criminal tax matters, the federal prosecutors that are pursuing taxpayers must be taken seriously, and it is essential that a taxpayer hire qualified legal representation.