Tip #8: Disabuse Your Client of the Notion That if the Audit Turns Criminal, He Can Just Pay Up and Move On
Your client will likely believe that if the audit turns criminal, that he can merely pay up and move on – with the expectation that the criminal problem will go away. It won’t. Payment of the tax won’t deflect a criminal investigation or prosecution. In appropriate cases, payment may permit your client to urge that he really wanted to pay the taxes that he owed all along and, when first advised that he may have underpaid, moved promptly to pay.
However, the government cannot generally accept that as a resolution of the criminal case. If it did, then every target would simply pay the tax. And the criminal enforcement program would be rendered useless if every taxpayer who underreports his income could do so with the idea that, if caught, all that he would have to do is simply pay any taxes, penalties, and interest.
In accordance with Circular 230 Disclosure
As a former public defender, Michael has defended the poor, the forgotten, and the damned against a gov. that has seemingly unlimited resources to investigate and prosecute crimes. He has spent the last six years cutting his teeth on some of the most serious felony cases, obtaining favorable results for his clients. He knows what it’s like to go toe to toe with the government. In an adversarial environment that is akin to trench warfare, Michael has developed a reputation as a fearless litigator.
Michael graduated from the Thomas M. Cooley Law School. He then earned his LLM in International Tax. Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of taxation make him uniquely qualified to handle any white-collar case.
Recent Comments