Tax Evasion Attorney in Manassas

Facing a Federal Tax Investigation? Put Former-Prosecutor Experience on Your Side

Contact from IRS Criminal Investigation, an interview request, a subpoena, or a federal charge may put your liberty, finances, business interests, and reputation at risk. provides federal criminal defense for people facing tax evasion allegations in Manassas and throughout Northern Virginia.

An audit, unpaid balance, filing error, or tax dispute is not automatically criminal tax evasion. Before providing substantive information to a special agent or another federal investigator, it is important to understand the nature of the contact, what the government is seeking, and how your response could affect the investigation.

Our attorneys include former prosecutors, and members of our team have experience working with law enforcement and investigating complex financial matters. We apply that background when evaluating serious white-collar investigations.

Federal Tax Evasion Under 26 U.S.C. § 7201

Tax evasion under 26 U.S.C. § 7201 is a federal felony.

Prosecutors generally must prove three central elements:

• Affirmative Act: The government must identify intentional conduct allegedly used to evade the assessment or payment of tax rather than relying solely on passive nonpayment or another omission.
• Tax Due & Owing: Prosecutors must establish that tax was legally due, which can require close analysis of income, deductions, credits, business records, and accounting information.
• Willfulness: The government must prove a voluntary and intentional violation of a known legal duty rather than confusion, negligence, or an accidental mistake.

Alleged affirmative acts can include concealing income or assets, filing a false return that omits business receipts, claiming false deductions, altering records, using nominees, or taking other affirmative steps intended to conceal a tax liability.

Failure to file a return, standing alone, can implicate a different federal tax offense and should not automatically be treated as satisfying the affirmative-act requirement for felony tax evasion.

A conviction under § 7201 can carry up to five years of imprisonment and a fine of up to $100,000 for an individual, in addition to other penalties and potential costs of prosecution.

An investigation can also involve separate allegations involving false tax returns, willful failure to file or pay, conspiracy, obstruction, employment taxes, or other federal offenses. The statute and potential exposure depend on the specific conduct the government alleges.

How IRS Criminal Investigation Develops Cases

IRS Criminal Investigation investigates potential criminal violations of the Internal Revenue Code and related financial crimes.

An inquiry may originate from information developed during an IRS audit or collection matter, a public report, another law-enforcement investigation, or information provided by a United States Attorney's Office.

Once a criminal investigation is opened, special agents may review tax returns, bank statements, business records, financial transactions, digital evidence, communications, and witness information. Investigators may conduct interviews, review financial data, perform surveillance, and execute search warrants. The government may also obtain records through subpoenas, summonses, or other lawful process.

Not every IRS criminal investigation leads to prosecution. An investigation may close without charges, proceed through additional internal review, result in a prosecution recommendation, or expand to other alleged offenses depending on the evidence.

If IRS-CI recommends criminal prosecution in a tax case, the matter may ultimately be referred to the Department of Justice for review.

Building a Defense Around the Evidence

We evaluate the government's evidence rather than assuming its interpretation of financial records is correct.

The available defense strategy depends on the alleged conduct, tax periods involved, financial documentation, investigative history, and potential charges.

Our analysis may address:

• Willfulness: Whether the evidence proves an intentional violation of a known legal duty rather than misunderstanding, incomplete information, or error
• Tax Calculations: Whether the government can establish the claimed tax liability using reliable figures and legally supportable assumptions
• Financial Records: Whether bank deposits, business receipts, deductions, transfers, and accounting entries require additional context or reconstruction
• Investigative Procedure: Whether statements, searches, seizures, compulsory process, and evidence collection complied with applicable legal requirements
• Witness Evidence: Whether testimony is consistent, credible, and supported by the underlying records
• Related Allegations: How false-return, conspiracy, obstruction, or other federal charges may affect the broader defense strategy

Our attorneys include former prosecutors and members of the team who have worked closely with law enforcement. That perspective can help us examine how investigators assembled a case, identify the evidence prosecutors may consider significant, and develop a defense strategy based on the actual circumstances.