Tax Controversy

Our firm has particular expertise representing individuals, corporations, and other business entities in federal and state criminal tax matters, including individuals and corporations with tax compliance issues and the professionals who advise such taxpayers. In recent years, we have represented targets, subjects, and witnesses in large-scale investigations conducted by the Department of Justice into tax shelters marketed by major accounting firms and financial institutions. We have also counseled numerous clients in connection with matters arising out of federal and state authorities’ pursuit of offshore bank accounts, and we have helped dozens of individuals bring themselves into compliance by disclosing accounts through the Internal Revenue Service's Voluntary Disclosure Practice and corresponding state voluntary disclosure programs.

Our criminal tax practice includes representing clients in administrative investigations conducted by the IRS, grand jury investigations conducted by the Department of Justice or state prosecutors, at trial, in sentencing proceedings, and on appeals. We also counsel clients confronting “egg shell” audits involving sensitive issues and the potential for a criminal investigation.