Our Practices

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While under audit, issues may arise that while not necessarily illegal, may give the appearance of improper conduct.

 

Criminal Tax Investigations and Audit Defense

A civil tax audit at times may lead to a referral to Criminal Investigations (CI) if the civil agent believes that the taxpayer willfully committed tax fraud.

It is critical for anyone with a tax return or books and records that may be perceived by a revenue agent or revenue officer to contain ‘badges of fraud’ to immediately pause the audit and invoke his or her rights to engage an experienced taxpayer representative. Commonly referred to as ‘egg shell’ audits, we can navigate these fact sensitive issues and have a track record of successfully steering these matters clear of a criminal referral, or if already referred to CI, persuaded CI to have the exam returned to a civil track.

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