IRS Criminal Investigation Defense

IRS Criminal Investigation Defense for Individuals, Professionals, and Businesses

Contacted by IRS Criminal Investigation? Protect yourself before you respond. An IRS-CI inquiry can place your liberty, reputation, business, and financial future at risk. Early legal guidance can help you avoid preventable statements and preserve critical defenses.

An IRS-CI Matter Requires a Criminal-Defense Strategy

A visit, telephone call, summons, or request for an interview from an IRS-CI special agent is not a routine collection notice. Criminal investigators focus on whether conduct was willful and whether the evidence supports referral for prosecution. What you say, produce, or authorize at the beginning may shape the rest of the investigation.
The Law Offices of Walter A. Reynoso, P.A. represents individuals, professionals, and businesses facing sensitive government investigations. We work to control communications, evaluate exposure, protect constitutional rights, and develop a defense grounded in the facts and the government’s burden of proof.

Warning Signs That a Criminal Tax Investigation May Be Underway

1. An IRS-CI special agent asks to interview you or arrives without an appointment.
2. You receive a summons for bank records, accounting files, payroll records, or testimony.
3. Employees, customers, banks, tax preparers, or business associates are contacted.
4. Agents ask about unreported income, cash transactions, deductions, payroll taxes, foreign accounts, or false documents.
5. A civil audit pauses, expands unexpectedly, or appears to involve a fraud referral.
6. A search warrant, seizure warrant, grand-jury subpoena, or target letter is issued.

How Our Firm Can Help

Take control of communications. We can communicate with agents and prosecutors, so you are not navigating interviews or document demands alone.
Assess your status and exposure. We examine whether you appear to be a witness, subject, or target and identify the statutes, tax years, entities, and transactions at issue.
Organize and test the evidence. We review returns, bank records, ledgers, payroll information, communications, and the work of tax professionals to evaluate intent and accuracy.
Protect privileges and defense strategy. When appropriate, counsel may coordinate with accountants or other professionals in a manner designed to support the legal defense.
Advocate before charges are filed. Where the circumstances permit, we present facts, legal issues, and mitigating information aimed at preventing or narrowing a prosecution referral.
Defend the case in federal court. If charges are filed, we prepare for motions, negotiations, trial, sentencing, and related financial consequences.

A Defense Built Around Context, Intent, and Proof

Criminal tax cases frequently turn on willfulness. Financial records may show what was reported or paid, but they do not always explain why a decision was made, what advice was received, who performed the work, or whether an error was intentional. We examine the full context rather than accepting the government’s first interpretation.

Representation Tailored to Professionals and Businesses

For professionals, executives, and business owners, an IRS criminal investigation can affect licensure, employment, ownership interests, reputation, and family stability—not merely a tax balance.
Professionals and executives. We account for licensure, employment, governance, and reputational concerns while addressing the investigation itself.
Closely held businesses. We separate individual and entity issues, identify decisionmakers, and review the flow of funds and responsibilities.
Tax-preparer and return issues. We examine communications, source documents, engagement scope, reliance, and who supplied or approved information.
Payroll and employment taxes. We analyze authority, control, payment decisions, payroll systems, and the allocation of responsibility.
Multi-agency or parallel matters. We consider civil tax, criminal, regulatory, licensing, and forfeiture consequences as parts of one coordinated strategy.

Our Approach

1. Confidential consultation. We learn what happened, how contact began, and what deadlines or demands are pending.
2. Immediate protection plan. We address communications, interviews, summonses, subpoenas, document preservation, and urgent risks.
3. Fact and financial review. We build a clear chronology and analyze the records with appropriate financial or tax professionals when needed.
4. Defense and resolution strategy. We challenge assumptions about willfulness, identify evidentiary weaknesses, and advocate at the investigation, charging, or litigation stage.