Atlanta Tax Fraud Lawyers

Atlanta Tax Fraud Lawyers

Jack Fisher and James Sinnott promised wealthy clients tax deductions worth 4.5 times what they paid. They sold over $1.3 billion in fraudulent conservation easement deductions. They used appraisals that valued land at 10 times what they paid for it. They backdated documents. They recruited appraisers, CPAs, and attorneys into their scheme. Fisher was sentenced to 25 years in federal prison. Sinnott was sentenced to 23 years. Combined restitution: over $900 million. The CPA and attorney who promised to save clients money will spend the rest of their lives paying it back from prison.

The Northern District of Georgia has seen tax fraud at a scale that dwarfs almost any other district. The Fisher/Sinnott conservation easement scheme represents one of the largest tax fraud prosecutions in Department of Justice history. 25 years for a tax crime. The case resulted in 11 additional guilty pleas from appraisers, CPAs, and attorneys who participated. When federal prosecutors in Atlanta bring tax charges, the consequences are measured in decades.

25 Years For The Conservation Easement Scheme

Jack Fisher was a certified public accountant who began selling units in abusive tax shelters at least as early as 2008. James Sinnott was an attorney who joined Fisher’s scheme in 2013 and oversaw massive expansion of the fraudulent deduction amounts claimed from the IRS. Together, they designed, marketed, and sold syndicated conservation easement tax shelters to high-income clients.

The promise was simple. Pay a certain amount, receive deductions worth 4.5 times what you paid. The mathematics were too good to be true – becuase they were fraudulent.

Heres how the scheme worked. Fisher and Sinnott used client funds to buy land and property holding companies. Then they had the tax shelters cause the companies to donate the land or conservation easements – often within days or weeks of purchase. To reach the inflated values needed for the deductions, they used appraisals that valued the property at often more than 10 times what they actualy paid.

Think about what that required. An appraisal claiming land is worth 10x its purchase price. Documents backdated to make transactions appear legitimate. Subscription agreements falsified. Payment records fabricated. The scheme wasnt just false returns – it was a systematic manufacturing operation for fraudulent deductions on an industrial scale.

The evidence showed Fisher and Sinnott backdated or instructed others to backdate false documents to present to the IRS. Subscription agreements. Payment documents. Engagement letters. Everything needed to make the fraud look legitimate was fabricated after the fact. The paper trail was manufactured.

Fisher was sentenced to 25 years in federal prison. Sinnott was sentenced to 23 years. Those sentences are effectively life terms – Fisher is a CPA, Sinnott is an attorney, and both are middle-aged. They will spend their remaining productive years in federal prison. The restitution orders are staggering:

• Fisher owes approximately $457,855,755 to the United States
• Sinnott owes approximately $443,760,035
• Combined restitution exceeding $900 million that they will never be able to repay

The Network That Went Down Together

The conservation easement scheme didnt operate in isolation. It required appraisers willing to inflate values. CPAs willing to prepare the returns. Attorneys willing to structure the transactions. Each participant added credibility to the fraud – and each participant became a defendant when the scheme collapsed.

To date, in addition to Fisher and Sinnott, nine additional defendants have pleaded guilty to criminal conduct related to the scheme:

• Appraiser Walter Douglas “Terry” Roberts
• Accountants Stein Agee and Corey Agee
• CPAs Ralph Anderson, James Benkoil, Victor Smith, William Tomasello, and Herbert Lewis
• Attorney Randall Lenz

The network that made the fraud possible became the conspiracy that prosecutors proved.

Vi Bui was an attorney and partner at Sinnott & Co. Beginning at least in 2012 and continuing through at least May 2020, Bui participated in organizing, marketing, implementing, and selling illegal syndicated conservation easement tax shelters. He was sentenced to 16 months in federal prison for obstructing the IRS. The partner who helped run the scheme got the shortest sentence – but still went to prison.

Heres the thing about conspiracy charges. Everyone who participates becomes liable for the entire scheme. The appraiser who inflated one valuation becomes connected to $1.3 billion in fraudulent deductions. The attorney who structured one transaction becomes part of a conspiracy spanning years. The CPA who prepared returns using the fake appraisals becomes a co-conspirator. When the scheme collapses, everyone connected goes down together.

For anyone in Atlanta who participated in a conservation easement scheme or similar tax shelter, the Fisher/Sinnott case should be terrifying. The investigators traced the entire network. The prosecutors charged everyone they could connect to the scheme. The sentences ranged from 16 months to 25 years. And the clients who bought the deductions? There returns are now subject to IRS examination. The deductions they claimed may be disallowed. The taxes they thought they saved may become debts they owe – with penalties and interest.

1,261 Fraudulent Returns In Two Years

Jessica Crawford operated a tax preparation business in Athens, Georgia. In tax years 2020 and 2021 alone, she filed 1,261 tax returns. An IRS statistical review determined that she fraudulently filed returns resulting in losses to the IRS exceeding $3 million from falsely claimed credits. Her sentence: 96 months in federal prison. Eight years.

Consider those numbers. 1,261 returns in two tax years. Thats over 600 returns per year. Nearly two fraudulent returns filed every single day. The scale required treating fraud like an assembly line – process clients, fabricate credits, file returns, collect fees. Crawford wasnt making occasional mistakes. She was operating a fraud factory.

Crawford also filed false Pandemic Unemployment Assistance claims during COVID. She recieved a portion of the benefits. The COVID fraud added to her charges. The tax preparer who was already committing tax fraud used the pandemic to add another revenue stream of fraud.

The 8-year sentence reflects the scale. $3.5 million in false returns. 1,261 clients whose returns are now suspect. COVID fraud on top of tax fraud. The woman who promised to help clients with there taxes created problems that will follow those clients for years. Every return Crawford filed is now in IRS systems as prepared by a convicted fraudster. Those returns may be examined. Those clients may face audits and repayment obligations.

Heres the uncomfortable truth about tax preparer fraud in Atlanta. The Crawford case isnt unique – its just the largest recent example. Ghost preparers operate throughout the metro area. Fraudulent EIC claims are filed constanty. False Schedule C businesses are created to generate deductions. The infrastructure for tax fraud is extensive, and the clients who use these preparers inherit the consequences when the preparer gets caught.

The Ghost Preparer Networks Of Augusta

Allen Brown operated as a “ghost” tax preparer in Augusta, Georgia. Ghost preparers hide there identity – they fail to identify themselves as paid preparers on the returns they file. The anonymity is supposed to protect them. It dosent.

Brown fabricated income to qualify clients for tax credits. He claimed fake deductions to boost refund sizes. He charged clients a percentage of their refund – which created an incentive to maximize the fraud. The bigger the fraudulent refund, the more Brown got paid. He and other ghost preparers working with him falsified 63 federal income tax returns, causing the U.S. Treasury to issue $1,003,631 in false refunds.

His sentence: 46 months in federal prison. Nearly four years for the ghost who thought he was invisible.

Kim Brown – a separate defendant, also from Augusta – operated similarly. She was sentenced to 22 months in federal prison after pleading guilty to aiding and assisting in the preparation of false returns. Her restitution order: $541,912. The ghost preparer tactic didnt protect either of them. The IRS traced the patterns. They identified the clusters of returns with similar fabrications. They followed the money back to the preparers who filed them.

Heres the thing about ghost preparer networks. They often work together. Multiple preparers filing similar fraudulent returns. Sharing techniques. Building client bases. When one gets caught, investigators follow the connections to the others. The Brown cases in Augusta show how networks get dismantled – one conviction leads to another, and the ghost preparers who thought they were hidden become defendants who face years in prison.

The Tax Preparer Who Evaded His Own Taxes

Samir Patel worked as a tax return preparer at a national return preparation business from 1999 to 2021. In 2015, he purchased a franchise in Claxton, Georgia, where he hired, trained, and supervised tax preparers while continuing to prepare returns for customers. He was a professional. He understood tax obligations. He prepared returns for others showing them how to comply with the law.

And he evaded his own income taxes for years.

Patel filed false returns for 2015 through 2017 that omitted over $1.28 million in income. The tax loss to the IRS: approximately $550,000. He was sentenced to two years in federal prison, ordered to pay a $95,000 fine, and ordered to pay $551,450 in restitution.

Heres the irony. The man who ran a tax preparation franchise – who taught other preparers – who filed returns for paying customers – didnt report his own income. He understood exactly what the law required. He helped clients comply. And he chose not to comply himself. The tax preparer became the tax evader.

The Patel case shows what prosecutors call “consciousness of guilt.” A tax preparer who omits $1.28 million from his own returns cant claim ignorance. He knew the law. He applied the law. He chose to break the law for himself while following it for clients. That deliberate choice makes prosecution easier and sentences harsher.

The $1.28 million in unreported income over three years represents substantial earnings that Patel simply failed to report. The $550,000 tax loss represents what the IRS should have recieved. The two-year prison sentence represents the consequence for a professional who should have known better. The clients who used Patel’s franchise for there own tax preparation trusted a preparer who wasnt even following the law himself. The professional who taught others how to comply became the defendant who had to explain why he didnt.

Georgias Dual Prosecution Reality

Georgia has a state income tax with rates up to 5.49%. Unlike Tennessee or Nevada with no state income tax, Georgia has both state AND federal tax fraud enforcement. The Georgia Department of Revenue investigates state tax crimes. Federal prosecutors in the Northern, Middle, and Southern Districts of Georgia handle federal cases.

For tax fraud exposure in Atlanta, this creates significant consequences. You face BOTH state AND federal prosecution. A single fraud scheme can trigger investigation by the Georgia DOR AND the IRS simultaneosly. Cases can be prosecuted at the state level, the federal level, or both.

Heres what that means in practice. State prosecution carries its own penalties under Georgia law. Federal prosecution carries sentencing guidelines that result in years of prison time – up to 25 years in the Fisher case. The dual system means more investigators looking for fraud and more prosecutors available to bring charges. Atlanta residents face exposure that residents of Tennessee or Texas dont – becuase those states have no income tax to violate.

The three federal districts covering Georgia each handle tax cases:

• The Northern District of Georgia in Atlanta handles cases from the metro area – including the Fisher/Sinnott conservation easement scheme
• The Middle District handles cases like Jessica Crawfords 1,261 fraudulent returns in Athens
• The Southern District handles cases like the ghost preparer network in Augusta

Wherever the fraud occurs, theres a federal district ready to prosecute.

The coordination between districts means cases cant be avoided by operating across district lines. A preparer in Atlanta filing fraudulent returns for clients in Augusta triggers investigation from multiple directions. The ghost preparer networks that span multiple cities face prosecution wherever there strongest cases exist. The geography dosent create protection – it creates multiple points of vulnerability.

The Districts Approach To Major Fraud

The federal districts of Georgia have demonstrated through case after case that they will pursue tax fraud aggressivly. Jack Fisher – 25 years for the conservation easement scheme. James Sinnott – 23 years as co-conspirator. Jessica Crawford – 8 years for 1,261 fraudulent returns. Allen Brown – 46 months for ghost preparer fraud.

Heres the reality of federal tax investigations. By the time charges get filed, investigations have been running for months or years. The Fisher/Sinnott investigation traced the entire conservation easement network – promoters, appraisers, CPAs, attorneys. The Crawford investigation analyzed 1,261 returns filed over two tax years. The Brown investigation identified ghost preparer networks operating across Augusta. The evidence is gathered before defendants know there being investigated.

The sentences are extraordinary. 25 years for Fisher – one of the longest tax fraud sentences in recent history. 23 years for Sinnott. 8 years for Crawford. The restitution orders are massive – Fisher owes $458 million, Sinnott owes $444 million, Crawford owes millions. These debts follow defendants permanantly. They survive bankruptcy. They attach to future earnings forever.

And the 90% federal conviction rate means most people who get charged get convicted. Federal prosecutors in Georgia dont bring cases they cant prove. By the time your indicted, theyve already determined the evidence is sufficient. The investigation that happened without your knowledge produced the evidence that will convict you.

Defense Strategy In Atlanta

If your facing tax fraud exposure in Atlanta, the calculus involves understanding the scale of prosecution in this district.

The Fisher/Sinnott case shows what happens when sophisticated schemes get prosecuted – decades in prison. The Crawford case shows that high-volume preparer fraud results in years of prison time. The ghost preparer cases show that hiding your identity dosent prevent prosecution.

Heres what these cases have in common. By the time defendants faced prosecution, there options had narrowed dramaticaly. The investigations were complete. The evidence was gathered. The schemes were documented. The networks were mapped. The only questions were conviction and sentencing.

The time to address tax fraud exposure is before any of that happens. Voluntary disclosure programs exist. Coming forward before the IRS finds you creates opportunities to resolve issues civily – with penalties and interest, but potentialy without prison. The IRS actualy encourages this approach. And in Georgia, addressing issues proactivly can prevent state prosecution from developing alongside federal exposure.

If an investigation has already begun, damage control becomes the priority. Understanding what investigators know. Protecting against self-incrimination. Navigating toward the least damaging outcome possible. And if you participated in a conservation easement scheme or similar tax shelter, understanding that the entire network may be under investigation – the appraisers, the promoters, the attorneys, and the clients who claimed the deductions.

The voluntary disclosure window closes once an investigation begins. The IRS dosent accept voluntary disclosures from people who are already under investigation. If youve recieved a target letter or know agents are looking at your returns, the disclosure option has already passed. Defense strategy at that point focuses on minimizing exposure – negotiating charges, cooperating where appropriate, and preparing for trial if necessary.

Why Atlanta Specificaly Creates Exposure

Atlantas economy creates particular tax fraud exposure. The concentration of high-net-worth individuals targeted by conservation easement schemes. The extensive tax preparation industry serving the metro area. The networks of professionals – CPAs, attorneys, appraisers – whose cooperation is required for sophisticated fraud schemes.

The Fisher/Sinnott case reveals what happens when promoters sell to wealthy clients. The Crawford case shows how tax preparers can process over 600 fraudulent returns per year. The ghost preparer cases demonstrate how networks operate across the Augusta area. Each pattern represents a different type of fraud – and each type results in federal prosecution.

And the dual prosecution reality means Georgia residents face exposure that dosent exist in no-income-tax states. The Georgia DOR pursues violations of state tax law. Federal prosecutors handle IRS cases. Both systems are active. Both systems are effective. Both can pursue the same conduct simultaneosly.

If theres tax fraud exposure in your situation – returns prepared by someone now under investigation, conservation easement deductions you claimed, income you didnt report – the time to address it is before anyone starts looking. Not after the investigation begins. Not after your preparer gets sentenced. Not after the network you participated in gets dismantled.

Heres the thing about prosecution in Atlanta. The federal districts of Georgia have shown through the Fisher case, the Sinnott case, the Crawford case, and dozens of others that they pursue tax fraud aggressivly. The sentences are among the longest in the country – 25 years for Fisher, 23 years for Sinnott. The restitution orders exceed $900 million combined. The 90% federal conviction rate means most people charged get convicted. Your exposure persists untill you address it. The question is wheather you address it before investigators start looking or after prosecution becomes inevitable.