Selig & Associates
Kicking Ass and
Taking Names
Before we
review a single piece of paper, says David Selig of Selig & Associates, we
endeavor to have a true “heart-to-heart” with our client. If all goes well, we’ll
review their tax returns. If it’s really a serious matter, we’ll conduct a
forensic examination, including a detailed analysis of bank deposits, lifestyle
and spending habits. With this information, my colleague Attorney Bradley Dorin
can readily identify and assess the likelihood of criminal charges. We even
investigate the Agent who’s been assigned to the audit. Because some Revenue Agents
receive special training, and will attempt to obtain information that may be
used for criminal prosecution after the audit has begun. If necessary, we
assert all applicable privileges, says Attorney Dorin, including the Attorney-Client
Privilege, the Federally Authorized Tax Practitioner Privilege, which only
applies to tax advice in non-criminal tax matters. IRC §7525, Fifth Amendment
Privilege, Joint Defense Privilege and the assertion of Spousal Privileges. And
if the situation calls for it, we’ll even request that a proper record be kept throughout
the examination - and we’ll strive to protect you from making damaging statements
that the IRS agent will surely record. After the examination has wrapped up
we’ll obtain a copy of the record including IRS agent’s notes, say Selig, and
we’ll go over these notes with a fine-tooth comb.
Seven signs that your
Case is going Criminal
1.
The Revenue Agent seems unduly interested in your net worth and
bank records.
2.
The Revenue Agent mysteriously disappears. See: United States v.
Tweel, 550 F.2d 297 (5th Cir. 1977)
3.
The Revenue Agent makes contact with third parties.
4.
The Revenue Agent obtains search and seizure warrants
5.
The Revenue Agent asks about your “intent” etc.
6.
The Revenue Agent makes excessive copy requests.
7.
You receive summons or subpoenas for records
Seven Tax
Crimes that can Ruin your Day
IRC § 7201 – Willful attempt to evade or defeat tax (evasion)
IRC § 7202 – Willful failure to collect or pay over tax
(employment tax)
IRC § 7203 – Willful failure to file a return, supply
information or pay tax due
IRC § 7206 – Fraud or false statements (including aiding or
assisting in preparation of false returns)
IRC § 7212 – Willful attempt to interfere with administration of
internal revenue laws (obstruction)
18 USC § 286 – Conspiring to defraud the government
18 USC § 371 – Conspiring to commit offenses to defraud the
government
Selig & Associates shoots and scores
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