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

• Your bank notifies you that the Criminal Investigation Division (CID) of the IRS or the U.S. Attorney’s Office is requesting copies of your bank records.
• 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 sought representation by 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 cases 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/her.

Our criminal tax defense team possesses both of 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. In addition, we have an excellent reputation among the San Diego Criminal Investigations Division and with the San Diego United States Attorney’s Office. 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 investigation. 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. Even if the subject matter concerns someone else, you need to protect your rights.

For further assistance, contact our San Diego office.

For more information, please see:

• Criminal Tax Defense Main Page
• More about the Criminal Investigation Division
• Visit from an IRS Special Agent
• About IRS Criminal Investigations
• IRS Methods of Proving Tax Fraud and Tax Evasion
• Criminal Tax Attorney v. White Collar Defense Lawyers
• Criminal Investigation Division Tactics
• Tax Crimes
• Tax Crimes – Perjury