Getting Away With Murder (or in the alternative) Avoiding Criminal Tax Prosecution

Getting Away With Murder (or in the alternative) Avoiding Criminal Tax Prosecution

Criminal Prosecution of Tax Crimes must usually commence within 3 years of the crime, a/k/a. the dirty deed. See: IRC Sec. 6531. Of course, in the rough and tumble world of tax crime, every rule has an exception. Ergo, certain crimes take a good long time. That is to say, they have a 6 year waiting period. Examples include:

I.               Defrauding or attempting to defraud the United States or any agency thereof;

II.             Willfully attempting to evade or defeat any tax or the payment thereof;

III.           Willfully aiding or assisting in, or procuring, counseling, or advising, the preparation or presentation, under the Internal Revenue laws, of a false or fraudulent return, affidavit, claim, or document;

IV.           Willfully failing to pay any tax or make any return at the time or times required by law or regulations;

V.             Offenses set forth in IRC Sections 7206(1) and 7207 id est. false statements and fraudulent documents, and,

VI.           Offenses described in section 7212(a) id est. intimidation of officers and employees of the United States.

In addition to these ugly offenses, several Circuit Courts have held that willful failure to "pay over" withholding taxes under IRC Sec. 6531(4) is subject to the 6 year statute of limitations (the criminal side of the Trust Fund Recovery Penalty coin). Additionally, neither the 3 nor the 6 year statutory period runs when you’re out of the country or on the lamb (like a fugitive from justice on the run) See: IRC Sec. 6531.

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