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Criminal Investigations and Prosecutions

Marini & Associates PA is available to represents citizens of the United States, as well as resident and non-resident aliens, during all phases of criminal tax proceedings including:


  • Egg Shell Audits
  • Tax Evasion
  • Tax Fraud
  • Money Laundering
  • Unfiled Tax Returns
  • Amending Returns
  • Domestic Voluntary Disclosure
  • Undisclosed Offshore Account
  • Offshore Voluntary Disclosure
  • Grand Jury Investigation
  • Trials and Appeal 


Marini & Associates PA’s team of tax litigators use their >60 years of experience to counsel clients during investigations by the IRS and Department of Justice, as well as at the state level.

Marini & Associates PA’s tax controversy and tax litigation attorneys also work to bring clients into the tax system by utilizing applicable programs when available, such as the Offshore Voluntary Compliance Initiative or Last Chance Compliance Initiative.

When these initiatives are no longer available, Marini & Associates PA’s attorneys are adept at helping clients to become accepted in, and navigate through, the Voluntary Disclosure program of the IRS. By assisting clients in taking advantage of such programs, they may be able to avoid criminal prosecution.

If you know or suspect that you are or will be the subject of an IRS criminal investigation, before you talk to the IRS, contact Marini & Associates, PA for help.

A regular IRS civil tax audit can turn into a criminal investigation.  A taxpayer generally will not suspect they are being investigated until they are contacted by the IRS Special Agent. When a client becomes the target of an IRS investigation, our criminal tax lawyers will guide the client through each step of the process. We help our clients cooperate with investigators to the extent required by law, while fully asserting all available defenses, including the constitutional privilege against self-incrimination.

Once criminal tax charges are filed, our attorneys focus on developing the best tactics and strategies to successfully defend our clients.


Deferred Prosecution Agreements

The attorneys at our firm have extensive experience with Deferred Prosecution Agreements.  A Deferred Prosecution Agreement (a “DPA”) is an agreement between the government (usually, the Department of Justice) and a defendant where the government promises that it will not criminally prosecute the defendant to conviction so long as the defendant takes certain remedial actions. Once the defendant completes the promised actions, the government dismisses all criminal charges against the defendant, leaving the defendant without a criminal record. Defendants who violate the terms of the agreement are returned for prosecution.


Criminal Procedures

If you have failed to file your tax returns, under-reported your income, or knowingly claimed excess deductions, you may find yourself facing a criminal tax investigation. An IRS criminal investigation is a very serious matter, and criminal tax evasion and tax fraud have the potential to result in a criminal indictment and incarceration. If you know or have reason to believe that you are the target of an IRS criminal investigation, your best option is to contact experienced legal counsel immediately. Do not discuss your situation with IRS criminal investigators without legal advice. Legal counsel can make the difference between freedom and time spent in a federal penitentiary.

The typical criminal tax case is investigated by the Internal Revenue Service Criminal Investigation Division (CID). CID investigators are federal agents trained in law enforcement techniques and tactics. Many are accountants who often times have earned their CPA. CID offices are located in various IRS field offices throughout the country. CID special agents conduct a long, exhaustive investigation before deciding to recommend your case for prosecution. Special agents will attempt to interview you, many times your family, friends and business associates. Special agents will also intensively review your financial records looking for unexplained assets or wealth, and other signs of fraud.

Once a CID investigation is completed and the special agent in charge of the case recommends prosecution, the IRS conducts two more levels of review before a final decision is made by the IRS to forward the case to the United States Department of Justice Tax Division in Washington, D.C., for prosecution. At the U.S. Department of Justice Tax Division, federal prosecutors specializing in criminal tax violations once again review the case and make the final decision to prosecute or decline prosecution of the case. If the Department of Justice Tax Division in Washington approves prosecution, the case is sent to the local U.S. Attorney's office with the direction that the individual or individuals named be indicted and prosecuted for the offenses alleged.

In tax crime cases, the multi-tiered review and approval process can work to your advantage. There are a number of different opportunities available to the taxpayer and his or her counsel to derail a federal criminal case before it ever reaches a grand jury for indictment. At each of the IRS approval levels and at the Department of Justice Tax Division, your lawyer will have the opportunity to meet with government attorneys to attempt to convince them to decline prosecution of your case. If the government has a strong case against you, it is unlikely that he or she will be successful in avoiding prosecution. However, many times experienced counsel can convince the IRS or the Department of Justice Tax Division that the taxpayer made serious mistakes but did not intentionally engage in criminal conduct. In a criminal tax case, your attorney will have a number of opportunities to convince the government to decline prosecution prior to referral to the grand jury.

If you know or suspect that you are or will be the subject of an IRS criminal investigation, before you talk to the IRS,contact Marini & Associates, PA for help.

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