Has it been years since you've filed tax returns? While the
Internal Revenue Service may have not yet notified you, it will catch up to you
sooner or later. And with technology and sharing of information advancing at light-speed,
it may be sooner than you think.
The IRS may seek to impose a criminal offense for failure
to file tax returns as required. Even if you do file, the tax returns must be accurate
and truthful because, if the IRS detects false returns, a fraud referral to the
Criminal Investigation Division will be generated.
We represent numerous clients who have missed filing some
of their state or federal taxes. Some clients are only behind a year or two,
others need to catch up on their filings way back into the 1990's. Regardless of
complexity, our team of experienced
tax lawyers promptly prepares accurate back taxes,
while aiming to minimizing the risk of criminal prosecution andenforced tax collection by the taxing
Due to circumstances beyond their control, many of our clients
have lost their tax records, making the preparation of old back taxes more complicated.
Our tax lawyers often reconstruct and retrace client's tax records. By working closely
with the clients, our tax lwayers are able to prepare reasonably accurate tax returns.
have back taxes because they
do not have the money to pay the balancedue on the tax return. Our tax attorneys strongly believe that in
most circumstances, filing the missing tax returns is in the best interest of the
Although there are numerous reasons for timely
filing of the tax returns, the IRS can impose a penalty of up to 25% of the
tax due on a late tax return. In some status, a failure to file an income tax returnupon
request may also lead to a large penalty, even if you do not owe any tax.
help you file your back taxes!
The Internal Revenue Service is not limited to civil enforcement
of the tax laws; it could impose criminal charges leading to a conviction, fines
If an IRS Special Agent contacts you, this is an indication
that the Internal Revenue Service is conducting a criminal investigation. You will
be advised that you are not required to speak with the Special Agent and that you
may have an attorney present. Take this advice. Politely ask the agent to leave
and state that you wish to consult an attorney. Likewise, if you are currently under
criminal investigation and have been cooperating and talking with a SpecialAgent,
stop cooperating immediately and consult with an attorney.
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
If your accountant is subpoenaed to appear before the Grand
Jury and bring your records, a Federal Grand Jury is being utilized to conduct a
criminal investigation of you and/or your company. The Grand Jury is gathering evidence
at the request or referral of the IRS or another government agency. Since conversations
with your accountant are not protected under "attorney-client privilege,"
you should refrain from further discussion with your accountantuntil you have engaged
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 contain
either understatements of income or overstatements of deductions, or both, you should
refrain from further discussion with your accountant until you have engaged legal
counsel. Although this is initially only a civil audit, Revenue Agents are trained
to be on the lookout for and refer fraud red flags to the Criminal InvestigationDivision.
Existing "accountant-client privilege" does not extend to criminal investigations,
meaning that your accountant may be forced to provide details to the Internal Revenue
Service about your situation.
If any of these events happen to you, you should immediately
engage the services of a tax attorney who can monitor and respond appropriately
at the earliest stage in a criminal investigation, including obtaining copies of
bank records turned over to the IRS, quashing summons for information, utilizing
available legal privileges and defenses to limit personal records turned over to
a Grand Jury, and providing the best responses to an auditor's questionsand requests
for documents in a civil audit with criminal implications.
help you with criminal charges!
Click here for filing Back Taxes!