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 85% 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 that you have a potential criminal tax problem, I will have the best chance of arriving at a successful resolution. If you are facing a criminal tax matter, I can help you. I am one of the leading criminal tax attorneys in the US. Put my 27 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 "secret" offshore bank accounts.

To date, approximately 150 grand jury investigations of UBS clients have been initiated, of which 26 individuals have been criminally charged. From these 26 individuals, 22 have entered guilty pleas and the remaining 4 are awaiting trial. In addition, the Government have opened grand jury investigations into additional offshore banks across the world.

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 Criminal Division 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. Under no circumstances should you speak to the Special Agent.
• If you are under criminal tax investigation, the IRS may also obtain a search warrent to search your business and/or home.
• Taxpayers unfamiliar with the criminal tax process often think that if they just admit their mistakes and offer to pay the additional tax and some penalties, 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.
• 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 used unreported offshore tax bank accounts.
• 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 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 ...

     I am one of the leading criminal tax attorneys in the United States.

     Since 1984, I have successfully represented thousands of clients, including all types of criminal tax cases. I have the knowledge and 27 years of experience to help with any criminal tax matter.

In addition, for the past 18 years, I have taught 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).

I have been recognized as one of the Top San Diego County Attorneys in 2007, 2009 and 2010 by the San Diego Daily Transcript legal newspaper and was also named a "Super Lawyer" in 2008, 2009, 2010 and 2011.

     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 27 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 27 year legal career.

WARNING: Criminal tax law cases are very complex. Successful representation on a criminal tax law matter requires skill, plus criminal tax law knowledge and many years of experience. You need a "Super Lawyer" on your side.

EXPERT GUIDANCE ... During the past 27 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 ...   

I understand how a tax problem can take hold of your life and affect your ability to sleep at night. If you are serious about resolving your tax problem, I can help you. Please call me, San Diego tax attorney Richard Carpenter, at (619) 696-8607 to discuss your tax situation in complete confidence. Put my 27 years of tax law experience to work for you.

Hire A "Super Lawyer" To Resolve Your Tax Problems.
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RICHARD CARPENTER SAN DIEGO TAX ATTORNEY 406 Ninth Ave., Suite 213 San Diego, CA 92101 --------------

TELEPHONE: 619/696-8607
FAX: 619/696-0126
E-MAIL: rc4taxlaw@aol.com *
 
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