We frequently represent tax return preparers who find themselves the target of an IRS criminal investigation. These issues often start when the IRS picks up on issues with a client or two, who without any other excuse point the finger at the tax preparer to deflect the blame from themselves.
Internal Revenue Code Section 7206 makes it a crime for anyone to assist a taxpayer in the preparation and/or filing of a false tax return. Internal Revenue Code Section 7201 for tax evasion is also an oft used weapon by the IRS, as defendants don’t have to be evading their own taxes but can also get caught if they help others to evade a tax.
We recommend preparers contact us immediately if they believe there is an issue with one of their clients. The best defense is often a good offense to deal wit the issue and try to kill the criminal investigation before the IRS Criminal Division logs hundreds of hours in the investigation and gets a head of steam.
Eric L. Green, Esq.
Convicer, Percy & Green, LLP
60 Long Ridge Rd., Suite 202
Stamford, CT 06902
Ph. (203) 602-5550
Fax (203) 286-1311