Segal, Cohen & Landis, P.C.
IRS Criminal Investigation Defense — Attorney-Led Representation
IRS tax attorneys — Beverly Hills, CA. National representation.
When the IRS refers a matter to its Criminal Investigation Division (IRS-CI), the stakes shift from civil penalties to potential prosecution, prison time, and permanent reputational damage. Criminal tax cases involve tax evasion, tax fraud, filing false returns, failure to file, money laundering, and offshore account concealment.
IRS-CI is the most successful law enforcement agency in the federal government by conviction rate — over 90% of cases referred for prosecution result in conviction. If you are under criminal tax investigation — or believe you may be — you need an experienced criminal tax defense attorney immediately.
How We Help
Our Approach to Criminal Tax Defense Attorney
IRS-CI Investigation Defense
Criminal investigations often begin long before a subject knows they are under scrutiny. We identify whether you are a subject, target, or witness; assess the scope of the investigation; and develop a defense strategy from day one — including whether voluntary disclosure is a better path than waiting for prosecution.
Grand Jury Representation
Grand jury subpoenas can demand documents, financial records, and testimony. We review every subpoena, assert applicable privileges (attorney-client, Fifth Amendment), negotiate the scope of document production, and advise on testimony strategy.
Voluntary Disclosure (Pre-Charge)
In some circumstances, a voluntary disclosure to the IRS or Department of Justice before charges are filed can result in reduced exposure or civil resolution instead of criminal prosecution. We evaluate eligibility quickly and advise on whether this path is viable.
Trial Defense
If charges are filed, we represent clients from arraignment through trial. We challenge the government's financial evidence, cross-examine IRS agents, retain expert witnesses, and present a complete defense.
How It Works
The Resolution Process
Immediate Assessment
The moment you believe you are under criminal investigation, we assess whether you are a subject or target, identify the likely charges, and implement protocols to protect privileged communications.
Investigation Monitoring
We communicate with IRS-CI and DOJ Tax Division as your attorney of record, monitor subpoena activity, and manage any interviews involving associates or employees.
Defense Strategy Development
Based on the evidence we are able to identify, we build a legal and factual defense — challenging intent, the government's financial calculations, and the legal sufficiency of the alleged tax deficiency.
Negotiation or Trial
Most criminal tax cases resolve through negotiation before trial. We evaluate every plea offer against the trial risk and advise on the option that best protects your long-term interests.
Ready to Resolve Your Tax Problem?
Our attorneys have helped thousands of clients resolve IRS matters. Your consultation is free and confidential.
Common Questions
Frequently Asked Questions
What is the difference between civil and criminal tax fraud?+
Civil tax fraud carries a penalty of 75% of the underpayment. Criminal tax fraud can result in prison time (up to 5 years for tax evasion under IRC §7201), fines, and a permanent criminal record. The government must prove willful intent beyond a reasonable doubt in criminal cases.
Do I have to talk to IRS Special Agents?+
No. You have the absolute right under the Fifth Amendment to refuse to answer questions that might incriminate you. You also have the right to have an attorney present during any interview. Never speak to IRS-CI agents without an attorney present.
Further reading
Beverly Hills · Los Angeles · National
Segal, Cohen & Landis, P.C.
9100 Wilshire Boulevard, 601 East Tower, Beverly Hills, CA 90212
Free Confidential Consultation