As your dedicated federal criminal defense attorney I am here to provide guidance and representation in any IRS investigation or potential prosecution related to unreported income under provisions of the Internal Revenue Code section 7201. My commitment is to zealously advocate for you ensuring that all legal avenues are explored and utilized to protect your rights and navigate through this challenging period professionally.
Compare experience, prosecution insight, and local federal court knowledge before you call. Results ranked by verified honors and case-fit criteria for IRS tax defense.
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IRS criminal investigations target alleged willful violations of the tax code — false returns, offshore account concealment, FBAR violations, employment tax fraud, and abusive tax schemes. Civil audits can escalate to criminal referrals without warning.
An IRS civil audit can turn criminal when a revenue agent refers the case to IRS Criminal Investigation (CI). Understanding the signs of escalation — special agent involvement, summons enforcement, or grand jury subpoenas — is critical to protecting your rights.
The IRS and DOJ aggressively pursue undisclosed foreign accounts. However, the willfulness standard for FBAR penalties requires knowing and intentional conduct — not negligence, forgetfulness, or reliance on a foreign bank's assurances.
The government prioritizes employment tax prosecutions because withheld payroll taxes are considered 'trust fund' taxes. But the responsible person determination — who had authority to direct payments — is often disputed and fact-intensive.
IRS criminal tax cases are won or lost on documents, intent evidence, and the credibility of the taxpayer's explanation. Early engagement shapes the entire trajectory of the case.
The IRS Voluntary Disclosure Practice offers a path to avoid criminal prosecution for taxpayers who come forward before an investigation begins. Timing is critical — once the IRS has your name from another source, the window closes.
Good-faith reliance on a CPA, enrolled agent, or tax attorney negates willfulness. Documenting the advice received, the information provided to the professional, and the taxpayer's good-faith reliance is the cornerstone of this defense.
IRS summons enforcement and search warrants in tax cases must comply with the Fourth Amendment and IRS procedural rules. Evidence obtained through improper summons procedures or overbroad warrants may be subject to suppression.
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3 attorneys matched · ranked by awards, prosecution experience, and local federal court relevance
More than 25 years defending clients, with over a decade as a federal prosecutor in the Southern District of California. Knows how the U.S. Attorney's Office builds cases — and exactly how to challenge them. Direct attorney representation, no associates.
Built for people facing investigations, indictments, or serious federal exposure who need a defense plan fast. Direct access to a former prosecutor who knows what the government is building before they file.
Positioned for clients who need a defense lawyer who understands how federal cases are built and how to challenge them at every stage — from investigation through sentencing. Free, confidential consultation.
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Served over a decade as an Assistant United States Attorney in the Southern District of California, prosecuting white-collar crime, drug trafficking, money laundering, and public corruption cases. Since entering private practice, has defended clients in federal courts across the country — bringing prosecution-side insight to every defense strategy. Recognized as Best Lawyer and named to Top Lawyers by the San Diego Daily Transcript. Admitted to the S.D. California, Ninth Circuit Court of Appeals, and the United States Supreme Court.
401 West A Street, Suite 1150, San Diego, CA 92101 · (619) 557-0100 · 3 blocks from the federal courthouse
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Legal Disclaimer: This informational resource presents featured matches based on practice area, location, professional background, verified honors, and client reviews. This is not an official Google, Chrome, or government endorsement. No attorney-client relationship is formed by using this tool or reading this content. Every case is different — consult directly with a qualified federal criminal defense attorney about your specific situation. Prior results do not guarantee similar outcomes.
About this site: this resource explains federal irs tax defense, investigation steps, penalties, and attorney selection so readers can understand the site purpose immediately.
The IRS typically audits returns that show unusually high deductions, complex transactions such as those involving foreign accounts or entities, and discrepancies between reported income and third-party information reports.
Yes, through an Offer in Compromise program, you may be able to settle your tax debts for less than the full amount if certain criteria are met, such as proving payment in full would cause financial hardship.
The IRS generally has ten years from the assessment date to collect taxes owed. However, this period can be extended if you file for bankruptcy or request an installment agreement and other circumstances that suspend the collection statute.
