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Federal Criminal and Civil Tax Matters

The Internal Revenue Services touches almost everyone's lives. Dealing with the IRS is unlike dealing with any other federal agency. The IRS has its own particular set of rules and regulations and one must know them well to deal with any complicated manner. The IRS has different rules for civil and criminal disputes.

Resolving Disputes with the IRS

Investigations of tax returns are conducted by revenue offices who examine tax returns for civil adjustments, and special agents for possible criminal violations.

The attorneys at Vaira & Riley are experienced in dealing with both types of investigations. In the civil area our attorneys have handled numerous examinations by revenue agents involving complex questions of tax income and deduction computations. We have been successful in negotiating settlements where the matter in dispute was in excessive of a million dollars.

In the criminal area, dealing with special agents is more precarious because the outcome can result in federal criminal charges which could result in fines and jail sentences. We have represented taxpayers in investigations involving failure to file, submitting false tax returns, and tax evasion. We have represented clients during investigations by special agents, and have handled numerous IRS summons.

The Tax Audit

The professional tax return preparer normally should not represent the taxpayer in a complicated examination by a revenue officer, as the preparer very well may be a critical witness. It is important to note that the federal government does not honor a privilege between the preparer and the taxpayer.

Vaira & Riley will usually employ an independent forensic accountant who deals exclusively with the attorneys. There is a privilege between the lawyer and this accountant, who is called a Kovel accountant, and this privilege is recognized by the IRS.

Protecting the Clients

The lawyers of Vaira & Riley have years of experience derived from prosecuting federal criminal tax cases as federal prosecutors, and defending civil and criminal tax investigations and cases for private clients. We are joined in these matters by forensic accountants, all former IRS agents. Together we can provide a depth of service to handle the most complex matters.

Early Intervention is Vital

"Early investigation by counsel is vitally important. Investigations tend to gain momentum as they proceed and it becomes increasingly difficult to persuade the Special Agent that a case lacks merit or to engage in effective damage control as time passes."

- Peter F. Vaira and Thomas W. Nihill, "Dealing with IRS Special Agents."

 Contact tax dispute attorneys at Vaira & Riley today to discuss your case.