Defense Against IRS Criminal Investigations
Most people think tax issues mean audits, not indictments. But when the IRS believes you’ve crossed the line from mistake to fraud, things escalate quickly—and quietly. If you’ve been contacted by IRS Criminal Investigation or received a federal target letter, you may be facing serious criminal charges with long-term consequences.
At Christian, Nisbet & Casillas, we understand how the government builds these cases—and more importantly, how to break them down. We’ve defended clients facing allegations of tax evasion, filing false returns, failure to report income, and related financial crimes. These cases are complex, but with the right strategy, they can be beat.
Common Federal Tax and Financial Crime Charges
Tax and financial fraud often fall under the following statutes:
26 U.S.C. §7201 – Tax evasion
26 U.S.C. §7206(1) – Filing false tax returns
18 U.S.C. §371 – Conspiracy to defraud the United States
18 U.S.C. §1956 – Money laundering
Bank fraud, wire fraud, mail fraud under Titles 18 §1341-1343
Structuring or failing to report large cash transactions (under the Bank Secrecy Act)
What’s important to understand is that the IRS doesn’t need to show that your entire return is fraudulent—just that you willfully tried to underpay, conceal, or mislead.
How IRS Criminal Investigations Begin
Federal tax cases typically don’t start with an arrest—they start with paper. You may receive:
A civil audit that quietly becomes criminal
A summons for documents or records
A visit or call from IRS-CI agents
A target letter from the U.S. Attorney’s Office
A grand jury subpoena
These early stages are where the government is gathering evidence—but it’s also where a skilled defense attorney can make the biggest difference.
Penalties and Consequences
Convictions for tax crimes can include:
Prison sentences of 3–5 years per offense
Substantial fines (often in six figures)
Restitution orders to the IRS
Asset forfeiture or seizure of bank accounts
Lifetime restrictions on licenses or business activities
Even if prison is avoided, the personal and professional fallout can be devastating.
What’s Changed Recently?
The federal government has stepped up enforcement of:
Cryptocurrency and offshore account violations
1099 income from gig work, consulting, and digital platforms
Employee Retention Credit (ERC) and COVID relief fraud
Aggressive write-offs and deductions by small businesses
Failure to report cash-based income (e.g., restaurants, contractors)
The IRS has expanded its tech capabilities and now partners with the DOJ, FBI, and foreign financial watchdogs to track down unreported income and money movement.
How We Defend Federal Tax Cases
1. Distinguish Mistakes from Crimes
The IRS must prove willfulness. Errors, poor bookkeeping, or reliance on bad tax advice are not enough. We work to show your intent was never criminal.
2. Challenge the Numbers
We work with forensic accountants and tax professionals to examine the government’s calculations and assumptions. Just because the IRS claims a number doesn’t mean it’s accurate.
3. Pre-Charge Resolution
If we’re brought in early, we can often negotiate settlements, restitution arrangements, or non-prosecution agreements—avoiding formal charges altogether.
4. Fight Selective Prosecution
If you’re being targeted unfairly or disproportionately compared to others in similar positions, we raise that issue in court.
5. Minimize Exposure
If plea negotiations are necessary, we push to eliminate jail time, reduce financial penalties, and preserve your ability to move forward with your business or career.
What to Do Right Now
Don’t ignore IRS or DOJ letters—they won’t go away
Don’t talk to agents without counsel—even if you think you’re helping yourself
Gather all tax records, correspondence, and evidence of payments
Call a federal criminal defense attorney immediately
Every document, every statement, every dollar matters. These cases are about more than tax returns—they’re about intent, credibility, and control.
Final Thoughts
Federal tax cases are not always about what you did—but about how it looks on paper. That’s why you need a defense team who can see beyond the numbers and tell your full story.
At Christian, Nisbet & Casillas, we defend clients in San Antonio and across Texas in high-stakes tax and financial investigations. When your business, your freedom, and your reputation are on the line, experience matters.
When the IRS stops asking questions and starts building a case…we’re that call.
