Criminal tax cases require proof of willfulness - that you knew the law and chose to break it. Most tax problems are civil and should stay that way; the defense’s first job is keeping them there. When charges do come, the record can still be fought: in a $4 million offshore tax evasion case, our client served no jail time.
How these cases are built.
Federal cases are investigated long before they are charged - often for one to three years. By the time an indictment arrives, the government has your records, your communications, and frequently a cooperating witness. That is why the single most important variable in the outcome is when the defense starts. Engaged early, counsel can shape charging decisions, protect you in interviews, and sometimes end the matter before it begins.
Sentencing exposure - and how it moves.
Federal judges sentence under the guidelines, and some counts carry mandatory minimums. But exposure is not destiny: loss amounts get contested, enhancements get challenged, roles get minimized, and mitigation gets built. Six months on a $12 million Ponzi case - when prosecutors pushed for years - is what disciplined guidelines work looks like in practice.
Defenses that actually work.
Intent is the battleground in most federal prosecutions - the government must prove you knowingly and willfully broke the law, not that something went wrong. Suppression of illegally obtained evidence, attacking the loss calculation, dismantling cooperator testimony, and pre-trial motions that narrow the case are how verdicts and dismissals get won. If there is a way to win your case, we will find it.
