Criminal Investigation Division (CID)

This division of the IRS is charged with investigating people who have committed federal tax crimes, gathering evidence, and referring those individuals to the Department of Justice – Tax Division for prosecution. With the recent rise in the number and notoriety of tax crimes, the IRS has been stepping up the enforcement. As with other divisions of the IRS, the number of special agents hired has dramatically increased and revenue agents and officers are screening routine civil matters with increasing scrutiny. CID receives tips from a variety of sources including referrals from when revenue officers or agents whom detect fraud, whistleblowers, local newspaper articles, and other law enforcement agencies.

CID Tactics

Unlike the civil divisions of the IRS, an offer to pay the tax owed will not deter a special agent’s investigation. Special agents are not confined by time limits to their investigation and have a variety of resources available to collect information for prosecution. During a criminal investigation, special agents attempt to gather as much information as possible on the target or targets of their investigation. Tools that special agents frequently utilize include:

Examining public records including department of motor vehicles registrations, asset searches, and real estate title changes
Contacting credit bureaus and examining your credit report
Picking up and going through the trash at your residence or business
Mail covers – having the post office provide a list of every piece of mail you or your business receives
Surveillance
Undercover operations
Interviews with third party witnesses, usually starting with those not likely to contact the target
Issuing third party summons
Search warrants
Personal interviews – often special agents will surprise you at home or other unexpected place early in the morning or late at night.

Is CID After You?

There is a high likelihood that you and/or your company are under criminal investigation if any of the following occurs:

If your bank notifies you that the Criminal Investigation Division of the IRS or the U.S. Attorney's Office is requesting copies of your bank records.
If you receive a notice from the IRS that one or more of your previous tax years are being audited AND you know that the returns filed contain either substantial understatements of income or overstatements of deductions, or both.

If this happens you should not have any further discussions with your accountant regarding the returns until you have engaged a qualified criminal tax attorney. Although this is usually a civil audit, Revenue Agents are trained to be on the lookout for fraud red flags and to refer potential fraud to the Criminal Investigation Division. The existing "accountant-client privilege" does not extend to criminal investigations so your accountant may be forced to tell the Internal Revenue Service what you have told him.

Criminal Tax Attorneys San Diego Our defense team possesses both the necessary skill sets you should consider when selecting representation. RJS Law combines the necessary technical tax experience and accounting background with a seasoned criminal trial practice. Our commitment to our clients is to obtain the most favorable resolution at the earliest possible juncture. We diligently work with the government to avoid invasive and costly investigations. Our firm frequently defends both targets and witnesses, making sure your interests are protected during every phase of the investigation. Should the matter escalate to trial, however, we pledge to fiercely and objectively defend your rights until the end.

The Internal Revenue Service can impose criminal charges leading to jail time, fines and penalties for failure to file a tax return, hiding assets to avoid tax, tax fraud and various others tax crimes.

If an IRS Special Agent contacts you, the Internal Revenue Service is conducting a criminal investigaion. Do not talk or give any information to any agent, as whatever you say can and will be used against you in a subsequent court trial.

If your bank notifies you that the Criminal Investigation Division of the IRS or the U.S. Attorney's Office is requesting copies of your bank records, there is a high likelihood that you and/or your company are under criminal investigation.

If you receive a notice from the IRS that one or more of your previous tax years are being audited AND you know that the returns filed contain either substantial understatements of income or overstatements of deductions, or both, you should not have any further discussions with your accountant regarding the returns until you have engaged a qualified criminal tax attorney. Although this is initially only a civil audit, Revenue Agents are trained to be on the lookout for fraud red flags and to refer potential fraud to the Criminal Investigation Division. The existing "accountant-client privilege" does not extend to criminal investigations so your accountant may be forced to tell the Internal Revenue Service what you have told him.

Contact our Criminal Tax Team today!

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