When Your Freedom Is On The Line
When the government wants to put you in a cage — we put ourselves between you and them.
What's actually happening
A criminal tax investigation does not look like an audit. It looks like a knock on the door, a Special Agent in a suit, a grand jury subpoena dropped on your accountant. By the time you find out it's happening, prosecutors have been building the file for months — sometimes years. Every sentence you say without counsel becomes a 302 memo that goes straight into the indictment binder. The cases the government brings are not random; they are pattern cases — money laundering, willful evasion, false returns, payroll tax diversion, conspiracy — and each one has a specific defense built into how the statute is written. We have stood between everyday people and federal prosecutors for over 30 years. We know exactly how these cases get built, exactly where they fall apart, and exactly what to do in the first 48 hours to keep an investigation from ever becoming an indictment.
Most common charges we defend
IRC § 7201
Up to 5 years per count. The government must prove willfulness — and willfulness is exactly where these cases die when defended correctly.
How we handle itIRC § 7206(1)
A felony even if no tax was owed. We attack materiality, knowledge, and the 'jurat' element prosecutors routinely overcharge.
How we handle itIRC § 7202 + TFRP
Trust-fund prosecutions and §6672 assessments destroy business owners faster than any other charge. We fight responsibility and willfulness on both fronts.
How we handle it18 U.S.C. §§ 1956-1957
Often tacked onto a tax case to multiply exposure. We separate the underlying conduct from the laundering element and dismantle the 'specified unlawful activity' chain.
How we handle it18 U.S.C. § 371 (Klein)
The government's favorite catch-all in multi-defendant tax cases. We isolate clients from co-conspirator statements and push for severance early.
How we handle itIRC § 7623
Whether you've been reported or want to report, the strategy is completely different. We do both — but never on the same matter, ever.
How we handle itHow we work
If a Special Agent has contacted you, your spouse, your accountant, or your employees — say nothing beyond your name and that you want counsel. Then call us, immediately. The first 48 hours decide most cases.
We meet in person or by privileged video. Everything you tell us is attorney-client and work-product protected. Your accountant is not — we put a Kovel agreement in place so accountant communications become privileged too.
We map the criminal exposure (CID, DOJ Tax) and the civil exposure (audit, TFRP, fraud penalty) on a single board, because the government coordinates them and so must the defense.
Most cases we win are won before charges are ever filed — through a properly handled CID interview, a Tax Division declination memo, or a quiet civil resolution that moots the criminal referral.
We prepare every case as if it will be tried, because that is the only posture that earns serious plea offers — and the only posture that wins acquittals when trial comes.
Every service in this category
Defense against federal money laundering charges under 18 U.S.C. §§ 1956-1957.
Read moreLegal guidance for whistleblowers and defense for those subject to whistleblower claims.
Read moreDefense against willful tax evasion charges under IRC § 7201.
Read moreDefense for employers facing payroll tax fraud and trust fund recovery penalties.
Read moreDefense against charges of filing fraudulent or materially false tax returns.
Read moreDefense against conspiracy charges related to tax fraud schemes.
Read moreIf you got a letter
The notices below are the most common entry points into a case like this. Tap any one for a plain-English breakdown of what it means and what to do next.
Notice Letter 525
You're being audited. The IRS wants to examine specific items on your tax return and is requesting documentation.
Notice Notice of Deficiency
This is your legal right to challenge the IRS in Tax Court before paying. Miss this deadline and you lose that right.
Notice CP2000
The IRS believes you didn't report all your income. They've received information (W-2s, 1099s) that doesn't match your return.
Notice CP59
The IRS has no record of your federal tax return for a prior year and is asking you to file it. CP59 is the IRS's first formal step toward filing a Substitute for Return (SFR) on your behalf — which almost always overstates what you owe.
Notice CP2501
CP2501 is the IRS's first letter telling you third-party income data (W-2s, 1099s, K-1s, 1099-NECs) doesn't match what you reported. It's the prelude to a CP2000 adjustment if you don't respond.
Forms you may need to file
Each form has its own page with step-by-step instructions and the mistakes that get returns rejected.
Form 1040-X
Used to correct errors on a previously filed Form 1040 — claim missed deductions, fix income, or respond to an IRS adjustment.
Form 2848
Authorizes a licensed attorney, CPA, or enrolled agent to represent you before the IRS — speak, sign, and negotiate on your behalf.
Form 8821
Authorizes a third party (lender, accountant, attorney) to receive and inspect your IRS tax information — without representation rights.
Real outcomes
Chadds Ford business owner facing IRC § 7201 tax evasion charges. Our defense team achieved a plea to a lesser offense with no prison time.
Delaware County professional facing IRC § 7206(1) charges. Pre-indictment representation resulted in declination by U.S. Attorney's Office.
Speak the language
Criminal Investigation Division — the law enforcement arm of the IRS responsible for investigating potential criminal violations of the Internal Revenue Code.
Foreign Bank Account Report (FinCEN Form 114) — a report required for U.S. persons with financial interest in or signature authority over foreign financial accounts exceeding $10,000 in aggregate value.
Foreign Account Tax Compliance Act — federal law requiring U.S. taxpayers to report foreign financial assets exceeding certain thresholds and requiring foreign financial institutions to report accounts held by U.S. persons.
Power of Attorney — authorization for a tax professional to represent a taxpayer before the IRS, typically granted via IRS Form 2848.
Substitute for Return — a tax return the IRS files on behalf of a taxpayer who has not filed. SFRs typically do not include deductions or credits the taxpayer may be entitled to.
From the journal
Tax Debt
What Should I Do if I Can't Afford to Pay the IRS?Opening a tax bill from the federal government that you cannot afford to pay is a stressful experience. Learn your options for IRS tax debt relief.
Tax Debt
What Should I Do If I Owe the IRS More Than $10,000?Discovering you owe the federal government a significant amount of money can be overwhelming. Here's what to do if you owe the IRS more than $10,000.
Business Tax
7 Mistakes You're Making with Delaware Franchise Tax Problems (And How a Tax Attorney Can Fix Them)Delaware might be famous for being business-friendly, but that doesn't mean franchise tax problems don't happen.
The IRS has lawyers. So should you.
ExploreWhen the IRS stops asking and starts taking — there's a legal counter to every move.
ExploreSpecialty tax matters — bankruptcy, foreign accounts, estate planning, payroll, gambling, and more.
ExploreBrowse every service we offer — criminal defense, tax resolution, audit, appeals, planning — in one place.
Service indexEvery Day You Wait, It Gets Worse
Penalties compound daily. Interest doesn't sleep. One call — free, confidential, attorney-client privileged — and you'll finally know exactly where you stand.
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