Criminal Tax Defense

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

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

IF AGENTS CONTACT YOU

Be respectful, do not obstruct, and do not guess or volunteer explanations. State that you want counsel before answering questions, then contact an attorney promptly.

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.

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.

Matters We Handle

• Alleged tax evasion or tax fraud
• False returns, false statements, or false documents
• Failure to file or report income
• Employment and payroll-tax investigations
• Conspiracy, money laundering, and related financial allegations
• Grand-jury subpoenas, search warrants, seizures, and interviews
• Investigations involving tax preparers, businesses, professionals, or foreign accounts

Frequently Asked Questions

Should I speak with an IRS-CI agent?

You may decline a voluntary interview and request counsel. Do not lie, destroy records, or interfere with an investigation. An attorney can evaluate the request and communicate on your behalf.

What if I have not been charged?

The pre-charge stage can be critical because the evidence and theory of the case are still developing. Early representation may help protect rights, preserve records, and address misunderstandings before positions harden.

Can my accountant handle this?

An accountant may be important to the financial analysis, but a criminal investigation calls for legal advice concerning constitutional rights, interviews, privileges, charging exposure, and defense strategy.

What should I bring to the consultation?

Bring any agent contact information, summons, subpoena, warrant, letter, deadline, and a short chronology. Do not alter or discard records.