Criminal Tax Defense

There are a variety of different crimes that can be alleged related to a taxpayer’s conduct.  Some are more pure tax crimes, while other related crimes may be alleged against taxpayers that are found in other areas of the United States Code.

What can be described as pure tax crimes include the following crimes described in the Internal Revenue Code (Title 26):

  1. Tax Evasion or Evasion of Assessment under 26 U.S.C. §7201;
  2. Willful Failure to Collect or Pay Over Tax under 26 U.S.C. §7202;
  3. Willful failure to file a return under 26 U.S.C. §7203;
  4. Fraudulent Withholding Exemption or Failure to Supply Information under 26 U.S.C. §7205;
  5. Fraud and False Statements under 26 U.S.C. §7206;
  6. Fraudulent Returns, Statements, or Other Documents under 26 U.S.C. §7207; and
  7. Interference with the Administration of Internal Revenue Laws under 26 U.S.C. §7212.

A few other crimes that could come into play as it relates to tax matters, including:

  1. Aiding and Abetting under 18 U.S.C. §2;
  2. Conspiracy to Defraud the Government with Respect to Claims under 18 U.S.C. §286;
  3. False, Fictitious or Fraudulent Claims under 18 U.S.C. § 287;
  4. Conspiracy to Commit Offense or to Defraud the United States under 18 U.S.C. §371;
  5. Fictitious Obligations under 18 U.S.C. §514; and finally
  6. Identify Theft under 18 U.S.C. § 1028(a)(7).