IRS Criminal Investigations

We have represented taxpayers and businesses from around the country in IRS criminal investigations.  We are able to do this because the statutes, rules, and procedures governing IRS criminal investigations are the same in all federal jurisdictions, and because we are either already admitted, or can be admitted to practice in any of the United States District Courts in all fifty States.

Criminal IRS investigations are most often conducted by IRS-CI Special Agents utilizing an administrative/investigative process.  In these types of IRS criminal investigations, IRS-CI Special Agents attempt to interview the target of their investigation, as well as third-party witnesses.  IRS-CI Special Agents may serve an Administrative Summons (Form 2039) on targets and witnesses in hopes of securing testimony and documents for their investigation.

In some cases, IRS criminal investigations are conducted by and through a United States Attorney utilizing a federal grand jury.  In these “Grand Jury Investigations,” IRS-CI Special Agents may serve grand jury subpoenas on targets and witnesses commanding personal appearances as well as the production of documents for the grand jury’s consideration.