In order to prove that a taxpayer committed tax evasion, the government must show three things beyond a reasonable doubt:
- An attempt to defeat or evade a tax or the payment thereof;
- An additional tax due and owing; and
- that the taxpayer’s actions were willful.
As your criminal tax attorney it is our job to demonstrate to the IRS special agent investigating your case that no tax crime took place and that the matter should be resolved in the civil division. If you are, or believe you are about to be investigated by the IRS’s Criminal Investigations Division or CID, you need to contact a tax lawyer as soon as possible.