How To Defend A USC Title 26 Criminal Referral To The Department Of Justice
Client was the subject of a Criminal Tax Investigation, being conducted by the Internal Revenue Service, for failure to pay withheld payroll taxes in excess of $800,000, for the years 2016, 2017 and 2018. After engagement, I commenced a review and parallel investigation of the allegations, to determine a defense. The Criminal Investigation Division, Special Agent completed his investigation, and made a referral to the Department of Justice, in 2023. After a thorough review of over 8,000 documents, secured through discovery, I located the ‘smoking defense gun’: correspondence from an Internal Revenue Service Appellate Officer, which stated that no payment