CRIMINAL TAX

     The biggest mistake anyone can make is to underestimate the seriousness of a criminal tax, tax evasion, false return, criminal failure to file or pay, or tax fraud matter. The IRS regularly obtains convictions in over 80% of their criminal tax cases. Under no circumstances should any taxpayer speak with an IRS criminal division Special Agent, without first consulting with an experienced criminal tax attorney. All statements made by a taxpayer to a Special Agent can be used against him or her in any subsequent court trial. By recognizing early on when there is a potential criminal tax problem, an experienced criminal tax attorney has the best chance of arriving at a successful resolution. If you are facing a criminal tax matter, San Diego tax attorney Richard Carpenter can help you. Put my 25 years of criminal tax law experience to work for you.

IMPORTANT: The IRS has put together a special criminal tax task force and their mission is to locate those Americans who have used offshore bank accounts - such as at UBS bank in Switzerland - to hide U.S. taxable income from the IRS.  The U.S. Justice Department and the IRS have teamed up together and they are now aggressively bringing criminal tax charges against those Americans with UBS bank accounts, and other offshore bank accounts, who did not file for the recent offshore tax settlement agreement offered by the IRS.   I am currently defending a former UBS bank account holder against IRS criminal tax charges in San Diego.  If you previously had a UBS bank account in Switzerland and you did not file for the recent offshore tax settlement agreement, the IRS will likely be coming after you very soon with criminal tax charges.  Please contact me immediately if you had an offshore bank account at UBS in Switzerland.

DID YOU KNOW THAT ...

• The most common way a criminal tax investigation gets started is by someone reporting you to the IRS for cheating on your taxes.
• The sole function of an IRS Special Agent is to obtain sufficient evidence to prosecute you for committing a tax crime.
• If you are under criminal tax investigation, an IRS Special Agent may make a surprise visit to your home or office. A search warrant may also be issued by a federal judge.
• Taxpayers unfamiliar with the criminal tax process often think that if they just admit their mistakes and offer to pay the additional tax, the Special Agent will simply go away. A criminal tax case is very different than a civil tax audit. Admitting your wrongdoings will merely bolster the IRS's criminal case against you and provide critical evidence which will later be used against you in Court.
• The IRS is now focusing on small and mid-sized businesses and self-employed individuals.
• There is no CPA-client privilege in a criminal tax case. Thus, the accountant who prepared your tax return can be forced to tell the IRS and a federal grand jury everything you have told him or her.
• Criminal tax cases are either handled as "administrative" or "grand jury" investigations.
• Tax evasion is the willful filing of a false tax return and is the most serious of all tax crimes.
• The IRS cannot obtain a conviction for tax evasion if a taxpayer was solely negligent or careless.
• The IRS cannot obtain a conviction for tax evasion if there is no tax deficiency (because of other unused deductions or credits). However, a tax deficiency is not necessary to obtain a conviction under the "perjury" tax crime charge.
• A taxpayer who willfully fails to file a required tax return can be sent to federal prison.
• The "perjury" tax crime is the most flexible criminal tax provision available to the IRS.
• A taxpayer who willfully delivers to an IRS agent a false document during a civil tax audit has committed a serious tax crime.
• Tax evasion can also occur when one fraudulently avoids the payment of tax by placing their assets in the name of a nominee.
• The IRS has only six years to prosecute most tax crimes, such as tax evasion, the "perjury" tax crime, and the failure to file a tax return charge.
• The IRS continues to aggressively prosecute individuals that use offshore tax havens
• Federal sentencing guidelines still play a major part in determining what sentence a taxpayer may receive in a criminal tax case.

SAN DIEGO TAX LAWYER RICHARD CARPENTER CAN HELP BY ...

• Evaluating your exposure to possible criminal tax charges.  
• Assisting prior to a criminal tax investigation with an "eggshell" audit.
• Providing an offshore credit card / bank account defense to criminal tax charges. 
• Planning a proper defense strategy if a criminal tax investigation has already begun.
• Effectively representing you throughout the entire administrative and court process if you have been charged with any tax crime.

RICHARD CARPENTER's EXPERIENCE ...

     Since 1984, I have successfully represented more than one thousand clients, including all types of criminal tax cases. I have the knowledge and 25 years of experience to help with any criminal tax matter.

In addition, I teach the Criminal Tax Fraud class as a part time Tax Law Professor at the University of San Diego School of Law. I am also a Certified Tax Law Specialist, and the author of 14 published articles, one of which is a leading article concerning criminal tax ("PRACTICAL GUIDE TO UNDERSTANDING CRIMINAL TAX MATTERS", published in Taxation For Accountants, May 1998 and republished in Taxation For Lawyers, July/August 1998 issue).

     Unlike some criminal tax defense attorneys, I did not start out my legal career as a federal prosecutor working to put good people in prison for some mistakes on their tax returns. Instead, I have devoted my entire 25 year legal career helping to defend hardworking, family-oriented taxpayers against the far and powerful reaches of the Internal Revenue Service and I am proud of that accomplishment. Being an effective criminal tax defense attorney is a mindset and I have had that criminal tax defense mindset for my entire 25 year legal career.

WARNING: Criminal tax law cases are very complex. Thus, it is very important that you hire only an experienced, State Bar Certified tax attorney to represent you and that you carefully review their criminal tax defense experience background before you hire them. I recommend a minimum of 15 years of criminal tax defense experience. Successful representation on a criminal tax law matter requires skill, plus criminal tax law knowledge and many years of experience. It is certainly not a job for a novice attorney.

EXPERT GUIDANCE ... During the past 25 years, many attorneys and CPA's have looked to San Diego Tax Attorney Richard Carpenter for expert guidance in helping their clients resolve serious tax problems with the IRS. For a complete description of my background, please click here.     

HELP IS AVAILABLE TO YOU ...   

If you are serious about resolving your tax problem, I can help you. Please call me at (619) 696-8607 to discuss your tax situation in complete confidence. Put my 25 years of tax law experience to work for you.

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RICHARD CARPENTER
SAN DIEGO TAX ATTORNEY
406 Ninth Ave., Suite 213
San Diego, CA 92101
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TELEPHONE: 619/696-8607
FAX: 619/696-0126
E-MAIL: rc4taxlaw@aol.com *
 
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