Criminal Tax Defense

Minns & Arnett routinely defends clients in criminal investigations of tax fraud, evasion, failure to file, FBAR violations, and failure to pay cases against criminal tax investigations conducted by the IRS, the Tax Division of the Department of Justice, or local United States Attorneys’ offices. Minns & Arnett works with taxing authorities to avert criminal proceedings and eliminate or reduce penalties and civil tax assessments, while creating alternative resolutions to indictment, whenever possible. Charges levied in criminal tax cases commonly include, but are not limited to:

  • Tax Evasion – Willful attempt to evade or defeat a tax assessment or its payment (26 U.S.C. § 7201).
  • Failure to Pay Taxes/Failure to File Tax Returns – Failure to pay taxes, file a return, keep records, or supply information (26 U.S.C. § 7203).
  • Falsifying Tax Returns – This is often a misdemeanor version of the above-described felony for tax evasion (26 U.S.C. § 7207).
  • Making False or Fraudulent Statements – Applies to any person who willfully makes and subscribes any return, statement, or other document, which contains or is verified by a written declaration that it is made under the penalties of perjury, and which he or she does not believe to be true and correct as to every material matter (26 U.S. C. § 7206).
  • Conspiracy – Felony for two or more people conspiring to commit a tax offense or to defraud the IRS (18 U.S.C. § 371).
  • Obstruction of Justice – Attempting to interfere with the administration of Internal Revenue Laws or federal agents acting under the Tax Code (26 U.S.C. § 7212 and 18 U.S.C. § 1503).
  • Money Laundering – Financial transaction with sole or principal purpose of violating laws, including tax evasion or the making of false statements to the IRS (18 U.S.C. § 1956(a)(1)(A)(ii)).

Minns & Arnett also represents clients with previously undisclosed offshore bank accounts who make voluntary disclosure as well as those facing sanctions for failing to file Report of Foreign Bank or Financial Account (FBAR) information.

In order to provide clients with the most solid defense strategy possible, Minns & Arnett limits itself to representing only ten criminal tax cases at any given time. Unlike other firms, Minns & Arnett will never pressure an innocent client into accepting a plea agreement.