Criminal Tax
Our attorneys have extensive experience representing business entities and individuals in connection with governmental investigations of potential wrongdoing, including tax and white-collar crime investigations prosecutions. Gordon Rhea and Randy Andreozzi have successfully defended taxpayers in large multi-count criminal tax, money laundering, and RICO cases.
Criminal Tax
Our attorneys have extensive experience representing business entities and individuals in connection with governmental investigations of potential wrongdoing, including tax and white-collar crime investigations prosecutions. Gordon Rhea and Randy Andreozzi have successfully defended taxpayers in large multi-count criminal tax, money laundering, and RICO cases.
Our goal in defending clients accused of crimes is to avoid indictments and adverse publicity. Should an indictment occur, our lawyers wage a vigorous and tenacious defense at trial, and, if necessary, at sentencing and on appeal. Our extensive knowledge of both the tax codes and criminal procedure assure an effective defense for our clients.
Our professionals understand the intricacies of representing clients accused of federal and state crimes such as:
- Tax evasion
- Failure to file tax returns
- Conspiracy
- RICO
- Fraud
- Sales tax evasion
- Racketeering
- Illegally structuring financial transactions
- Foreign Bank Account Reporting (FBAR) penalties
- Payroll tax penalties
Latest News
IRS Captive Insurance Global Settlement Offer- Know your options.
By: Randall P. Andreozzi, Esq. In 2016 the IRS issued Notice 2016-66, which identifies certain micro captive insurance transactions as potentially abusive. The Notice generally describes the abusive arrangement as one where ...
Read moreOur View on Cryptocurrency Taxes & the IRS
By: Randall P. Andreozzi, Esq. Cryptocurrency investors be warned. The IRS is coming for you. Over the course of several years, the IRS has methodically ramped up its efforts to tackle the burgeoning cryptocurrency market. ...
Read moreIRS Completes Unprecedented Campaign Targeting Employment Tax Crimes
By: Kevin Murphy, Esq. In our most recent blog post, we discussed the importance of timely payment of payroll taxes and how serious the IRS is taking the issue of criminalizing the Trust Fund Recovery Penalty. As a follow up, we ...
Read moreWHY YOU SHOULD ALWAYS PAY YOUR PAYROLL TAXES: A PRIMER ON TRUST FUND RECOVERY PENALTIES (PART 2)-CRIMINAL EXPOSURE
By: Kevin Murphy, Esq. In Part 1, of this blog, we explained and discussed the civil aspects of IRC 6672- the Trust Fund Recovery Penalty (TFRP). At the end of Part 1, we mentioned that the civil statute is virtually identical to ...
Read moreVoluntary Disclosure options for taxpayers after the closing of the OVDP
By: Tiffany D. Bell When the IRS closed the 2014 OVDP last fall, which had provided an avenue for taxpayers to come into compliance with any past offshore tax and information reporting, it left many taxpayers and tax ...
Read moreClient Privilege – When you have it & when you don’t may surprise you.
By: Gary P. Bluestein Many accountants incorrectly assume that their communications with their tax clients are always privileged and confidential. Unfortunately, sometimes tax cases can cross over into potential criminal exposure ...
Read moreIRS Offshore Voluntary Disclosure Program Will End on September 28, 2018
By: Randall P. Andreozzi, Esq. The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on September 28, 2018. The Agency ...
Read moreThe Threat of Parallel Investigations: When Civil Isn’t Civil
By: Justin J. Andreozzi, J.D.; Randall P. Andreozzi, J.D.; and Arlene Hibschweiler, MBA, J.D. While at one time, the IRS would discontinue a civil examination when it began a criminal investigation of a taxpayer, it is now the ...
Read moreTax Anxiety – Good News & Bad News
With the upcoming hype surrounding taxes as April 15th approaches, anxiety increases for those in tax trouble. A significant number of people have been contacted by the taxing authorities about missing tax returns, or are ...
Read moreThe 11th Circuit Court of Appeals Reverses Tax Court Ruling on Intervention in USVI Cases
On February 20, 2014, the United States Court of Appeals for the Eleventh Circuit released an opinion allowing the Government of the United States Virgin Islands (“USVI”) to intervene in three cases consolidated for ...
Read moreWe are a law firm built on Experience, Vision & Trust
Whether you need tax counsel for litigation, representation before the IRS, an advocate in tax controversies, or thorough tax analysis and objective consulting, our attorneys have the experience and obtain lasting solutions.