Los Angeles Criminal Tax Attorney Representation

When the IRS suspects a taxpayer acted intentionally, not by mistake, an audit can turn into a Criminal Tax matter with serious, immediate consequences. In Los Angeles, that shift often comes without much warning: a high-pressure examination, an unexpected outreach from an IRS special agent, a subpoena, or a target letter tied to a larger investigation.

The team of experienced tax attorneys, CPAs, and enrolled agents at Moskowitz LLP provides Criminal Tax representation for Los Angeles individuals and businesses at every stage from sensitive audits and IRS Criminal Investigation (CI) involvement to pre-indictment advocacy, negotiated resolutions, and court proceedings when litigation becomes unavoidable. We focus on protecting your rights, managing exposure, and guiding the process strategically because in Criminal Tax matters, small missteps can create lasting damage.

Key takeaway: In a Criminal Tax matter, your communications, records and “helpful” explanations can become evidence against you. If IRS Criminal Investigation Division (CID) reaches out, it’s advantageous to have experienced counsel step in before you respond or hand over information.  You are not obligated to speak or respond to the IRS yourself.

Call (213) 320-1880 or submit our confidential contact form to discuss your concerns. Our office is located at 10940 Wilshire Blvd #1600, Los Angeles, CA 90024.

Criminal Tax Representation vs. Civil Tax Matters

A criminal tax matter involves allegations of willful violations of federal tax law, which can lead to your jail time, large monetary penalties and evidence against you in an IRS civil case against you. That’s different from civil tax issues (audits, penalties, collections), and it can carry far greater risk, including (but not limited to):

• CID investigations and criminal referrals
• Indictment and federal prosecution
• Restitution, significant fines, and incarceration
• Long-lasting, collateral consequences (business disruption, licensing concerns, reputational harm, and more)

In Los Angeles, Criminal Tax exposure commonly originates from:

• Civil audits that uncover fraud indicators (“badges of fraud”)
• Referrals to IRS Criminal Investigation Division (CID)
• Information provided by banks, employers, third parties, whistleblowers, or cooperators
• Parallel scrutiny involving promoters, tax preparers, or related business entities

IRS Criminal Investigation (CID) Representation

IRS CID investigates suspected tax crimes. Once CID is involved, the process typically centers on evidence gathering not simply correcting a return or resolving an audit.

Representation During CID Investigations

Moskowitz LLP assists clients throughout CID matters, including (but not limited to):

• Early case evaluation and risk triage
• Managing contact with special agents (IRS agents that work in the CID) and other investigators
• Protecting constitutional rights and privilege considerations
• Planning and supervising document production and responses to summonses/subpoenas
• Building legal and factual positions addressing alleged willfulness
• Pre-indictment advocacy and negotiations with investigators, prosecutors, and other government representatives when appropriate

CID investigations can be lengthy. Our representation is designed to keep decisions disciplined during the investigation and avoid actions that inadvertently strengthen the government’s narrative.

Handling IRS Special Agent Contact

If an IRS special agent contacts you by phone, letter, or a visit at home or work, it should be treated as a serious criminal tax signal. You should not speak with anyone other than an attorney about this issue. Only communications with an attorney are protected by attorney-client privilege, which legally requires confidentiality of what you share with us and what we advise you. Conversations with non-attorneys, including CPAs, family members, friends, or colleagues, are not privileged, and those individuals can be compelled to testify about what you told them.

How we help right away

• Determine what the outreach means and your likely status (witness or target). A “target” is an individual the government is considering prosecuting. A “witness” is someone who provides information to assist the government’s case. It is important to understand that a person may initially be treated as a witness and later become a target as the investigation develops.
• Route communications only through counsel
• Avoid unprotected interviews and “off-the-record” explanations
• Establish a controlled approach to records and information requests
• Reduce risk from errors coming from inexperienced tax counsel

Do not meet with a special agent on your own. In Criminal Tax matters, even seemingly minor inaccuracies can be reframed as intentional conduct.  “False statements” can potentially lead to jail time.

Target Letters and Grand Jury Inquiries

A target letter or grand jury inquiry may indicate that prosecutors believe there is significant evidence or that they are actively building toward indictment. These situations call for focused, experienced Criminal Tax representation.

Moskowitz LLP assists with:

• Rapid assessment of exposure and potential charge theories
• Strategy and communication with the U.S. Attorney’s Office, as appropriate
• Subpoena management
• Proffer planning and risk analysis (when strategically appropriate)
• Coordinating defense strategy where civil and Criminal Tax issues overlap, which is likely

ERC Criminal Fraud Representation (Taxpayers and Promoters)

Enforcement activity involving the Employee Retention Credit (ERC) has created heightened risk for both taxpayers and those who promoted or prepared claims. Investigations may allege claims were inflated, fabricated, or knowingly improper.

We represent

• Businesses accused of submitting false or overstated ERC claims
• Owners and executives accused of willful conduct connected to filings
• Promoters, preparers, and consultants are alleged to have driven improper claims
• Clients facing parallel civil audits, repayment demands, and Criminal Tax scrutiny

ERC-related Criminal Tax matters are often time-sensitive and document-heavy, involving eligibility support, payroll records, marketing materials, communications, and filing representations. Early representation helps protect the record before assumptions harden into allegations.

Voluntary Disclosure Representation

In some situations, a voluntary disclosure and structured remediation may reduce Criminal Tax risk, particularly when noncompliance is discovered before the government initiates contact or obtains key information.

We help clients assess:

• Whether voluntary disclosure is realistic under the facts
• Factors involving timing and risk
• The safest method to correct filings and address exposure
• How to manage narratives, documentation, and supporting records

Voluntary disclosure is not automatic insulation. How it’s handled matters, and mistakes can increase Criminal Tax exposure.

Representation for Tax Evasion and Fraud Allegations

Many Criminal Tax investigations focus on alleged tax evasion or tax fraud, including underreported income, concealed assets, fabricated documentation, or making false statement.

Representation in tax evasion matters

Tax evasion theories commonly require the government to prove:

• A tax deficiency existed
• There were affirmative acts to evade tax
• The conduct was willful

Our approach centers on facts, intent, and legal standards challenging weak links, unsupported assumptions, and indirect proof methods where appropriate.

Representation for fraudulent filings and aiding-and-abetting allegations

Criminal Tax exposure can extend beyond the taxpayer. Investigations may involve:

• Return preparers
• Business partners
• Payroll/bookkeeping personnel
• Consultants and advisors
• Anyone alleged to have assisted, caused, or enabled a false filing

We represent clients facing allegations involving:

• False or fraudulent returns
• False statements in filings or during interviews
• Aiding and abetting or assisting in improper filings

Whistleblower and Cooperator Representation

Criminal Tax matters can expand quickly based on whistleblower reports or cooperating witnesses such as former employees, partners, competitors, third parties with access to communications and records, ex-spouses or “people who think they know something.”

Moskowitz LLP represents clients who are:

• Responding to allegations initiated by a whistleblower
• Managing exposure when an associate or co-defendant is cooperating
• Protecting their interests as the investigation broadens
• Evaluating cooperation or proffer options when legally and strategically appropriate

Because cooperators can shape the narrative early, quick, strategic representation is critical.

Our Approach to Los Angeles Criminal Tax Representation

Criminal Tax matters often start fast and then unfold through sustained investigative pressure. Our representation is built to:

• Stabilize the situation and prevent errors
• Control communications and preserve defenses
• Build a record of facts
• Pursue outcomes that reduce or avoid criminal charges when possible
• Prepare thoroughly for litigation when necessary

Contact a Los Angeles Criminal Tax Representation Professional

If you’ve been contacted by IRS Criminal Investigation Division (CID), received a target or witness letter, learned of a grand jury inquiry, or believe you may have criminal tax exposure (including ERC-related scrutiny), it’s worth involving experienced counsel promptly.  Involving a highly-qualified tax attorney at the earliest possible stage may stop an issue from becoming criminal altogether.

Reach out to Moskowitz LLP’s team of experienced tax attorneys, CPAs, and enrolled agents via our confidential contact form to discuss criminal tax representation and next steps, or call (213) 320-1880.