Milwaukee Criminal Tax Representation Attorneys

When the Internal Revenue Service (IRS) suspects a taxpayer has willfully violated federal tax laws, what begins as a routine audit can develop into a criminal investigation with serious financial, professional, and personal consequences. For Wisconsin business owners, executives, entrepreneurs, and high-net-worth individuals, criminal tax exposure may arise through an IRS Criminal Investigation (CI) inquiry, an unexpected visit from a special agent, a federal grand jury subpoena, or allegations involving unreported income and fraudulent tax filings. At Moskowitz LLP, Milwaukee tax attorney Travis DeLucenay, JD, CPA draws on his legal and accounting background to help defend clients that are targeted by criminal tax investigations. We assist clients with sensitive IRS examinations, criminal investigations, pre-indictment matters, voluntary disclosure evaluations, and, when appropriate, litigation.

Moskowitz LLP’s Milwaukee office is located at 1433 N Water Street, Milwaukee, WI 53202, near the Milwaukee River and the city’s Lower East Side. We serve individuals and businesses throughout Milwaukee County and the greater southeastern Wisconsin region. We also represent individuals and businesses throughout the state to include Dane county and all counties up north.

To discuss a potential criminal tax matter, call 414-200-0030 or contact our team to schedule a confidential consultation.

Recent Client Review

"Great experience with the team at Moskowitz. Had a real mess with some back tax issues. Received excellent service from Mary and Carey who dug in and stayed with it until all issues were resolved! It was worth the money I paid them to work with the IRS on my behalf. Everything was resolved and I am personally relieved and happy to recommend their services."

— Verified Google Review from Dave M.

Criminal Tax Representation vs. Civil Tax Disputes

Civil tax disputes generally focus on determining the correct amount of tax owed, resolving filing discrepancies, or addressing penalties and collection activity. Criminal tax investigations involve suspected violations of federal or state criminal laws, often requiring proof of willful conduct or other elements specific to the alleged offense. A criminal tax investigation may expose individuals to consequences beyond additional tax assessments, including:

• Federal Criminal Charges: Allegations involving tax evasion, filing false returns, or other federal tax offenses.
• Financial Penalties and Restitution: Criminal fines, restitution obligations, and potential civil tax liabilities.
• Incarceration: Certain criminal tax convictions can result in imprisonment.
• Professional and Business Consequences: Criminal proceedings may affect professional licensing, business relationships, employment, and reputation.
• Parallel Civil Proceedings: Taxpayers may face criminal investigations while related civil tax assessments or collection matters remain unresolved.

Criminal tax investigations can originate from discrepancies uncovered during an audit, referrals from other government agencies, financial institution reporting, whistleblower allegations, or information obtained during investigations involving business partners and third parties.

IRS Criminal Investigation (CI) Representation

The IRS Criminal Investigation Division investigates potential criminal violations involving federal tax laws and certain financial crimes. Unlike a routine civil examination, a criminal investigation focuses on gathering evidence that may support prosecution.

Representation During IRS Criminal Investigations

Our criminal tax representation services may include:

• Evaluating potential criminal tax exposure and relevant legal defenses.
• Communicating with IRS special agents and federal investigators when appropriate.
• Advising clients regarding constitutional rights and attorney-client privilege.
• Reviewing subpoenas, summonses, and requests for financial records.
• Coordinating lawful document preservation and production.
• Evaluating allegations of willfulness, concealment, or fraudulent reporting.
• Developing pre-indictment advocacy strategies when supported by the circumstances.

Criminal tax investigations can involve extensive financial records, multiple tax years, and complicated business transactions. Early legal representation can help clients understand their obligations and avoid preventable mistakes during the investigative process.

Responding to IRS Special Agent Inquiries

Important: Statements made during a criminal tax investigation can carry significant consequences. If an IRS special agent contacts you, you generally have the right to decline a voluntary interview and seek legal counsel before answering questions. However, subpoenas, summonses, and other legally enforceable demands must be evaluated separately and should never be ignored.

An unexpected contact from an IRS special agent should be taken seriously, particularly when the inquiry concerns business finances, tax filings, or potentially unreported income. Although individuals generally are not required to participate in voluntary interviews with federal investigators, they must comply with applicable legal obligations involving subpoenas and other compulsory processes. Our Milwaukee Criminal Tax lawyers help clients:

• Determine whether they are being approached as a witness, subject, or potential target.
• Establish appropriate communication procedures with investigators.
• Evaluate requests for interviews, documents, and financial information.
• Preserve relevant records and electronic communications.
• Understand the risks associated with statements made during an investigation.

Clients should not destroy, alter, or conceal records or make false statements to investigators. Legal counsel can help determine an appropriate response while protecting available rights.

Target Letter Representation and Federal Grand Jury Inquiries

Receiving a federal target letter or grand jury subpoena can indicate that prosecutors are investigating possible criminal conduct. For Milwaukee-area federal tax matters, these proceedings may involve the U.S. Attorney’s Office for the Eastern District of Wisconsin. Our Milwaukee Criminal Tax lawyers assist with:

• Criminal Exposure Assessment: Reviewing allegations, relevant financial records, and potential federal tax charges.
• Government Communications: Evaluating appropriate contact with federal prosecutors and investigative agencies.
• Grand Jury Subpoena Responses: Reviewing document requests, preservation obligations, and available legal protections.
• Pre-Indictment Advocacy: Assessing opportunities to present evidence or legal arguments before charging decisions are made.
• Parallel Civil and Criminal Proceedings: Coordinating strategies when tax assessments, audits, and criminal investigations overlap.

Because federal investigations can involve strict deadlines and substantial legal exposure, prompt review of government correspondence is important.

ERC Criminal Fraud Representation for Wisconsin Businesses

The Employee Retention Credit (ERC) has become a significant area of federal tax enforcement following widespread concerns about improper claims and fraudulent third-party promotion. Criminal ERC investigations may involve allegations that employers knowingly submitted false claims, overstated qualifying wages, misrepresented pandemic-related business disruptions, or participated in schemes involving improper refund payments.

Voluntary Disclosure Representation

Taxpayers who discover serious past reporting violations may have options for correcting their filings before an investigation begins. The IRS Criminal Investigation Voluntary Disclosure Practice provides a framework through which eligible taxpayers may disclose certain willful tax noncompliance. However, voluntary disclosure is not appropriate for every situation and does not guarantee immunity from criminal prosecution.

Wisconsin taxpayers may also need to evaluate separate state-level reporting and disclosure obligations. Federal voluntary disclosure does not automatically resolve liabilities or potential exposure under Wisconsin law.

Tax Evasion and Fraud Representation

Criminal tax investigations frequently involve allegations of deliberately underreporting income, concealing assets, falsifying financial records, or taking affirmative steps to evade tax obligations.

Defense Against Tax Evasion Allegations

Federal tax evasion charges under 26 U.S.C. § 7201 generally require the government to establish:

• The existence of a tax deficiency or tax due and owing.
• An affirmative act intended to evade or defeat tax.
• Willfulness.

Willfulness in federal criminal tax cases generally concerns a voluntary, intentional violation of a known legal duty.

Speak With a Milwaukee Criminal Tax Lawyer Today

If you have been contacted by IRS Criminal Investigation, received a federal grand jury subpoena, learned of a potential criminal tax referral, or are concerned about allegations involving tax evasion, fraudulent returns, or improper ERC claims, seeking legal representation promptly is important. At Moskowitz LLP, our tax attorneys and financial professionals assist individuals and businesses throughout Milwaukee and southeastern Wisconsin with complex criminal tax controversies.

Call 414-200-0030 or schedule a confidential consultation to discuss your situation and available legal options.