Taxpayers who find that they are the target of an IRS tax investigation for possible criminal tax violations are presented with difficult choices that often affect the ultimate outcomes of their cases.
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Plea agreements often call for the Defendant to plead guilty to certain counts of the indictment and for the government to dismiss the remaining counts. Occasionally, the government asserts that the Defendant has violated the plea agreement and the United States seeks to re-indict the counts it has dismissed. However, if this occurs after the defendant has been sentenced and has served his sentence, due process requires the government to move for the Court to declare the defendant in violation of the plea agreement and grant the government leave to convene the grand jury to re-indict the defendant on the charges previously dismissed. The government cannot summarily declare the defendant in breach of the plea agreement and re-indict him without a determination by the court. This situation occurred in the following tax case.
If you learn that you may be the target or subject of an IRS criminal tax investigation it is imperative that you not answer any questions and retain a lawyer with extensive criminal tax trial experience.
Evidence of zero tax loss may be excluded in a tax case charging the taxpayer with willfully filing fraudulent tax returns pursuant to 26 U.S.C. Section 7206.
If you learn that you are the target or subject of a federal investigation for possible tax violations and/or related economic crimes, what is the best way to select the best tax lawyer to represent you?