Tampa Tax Evasion Defense Attorney

A federal tax investigation can put your freedom, finances, career, business, and reputation at risk. If you believe the Internal Revenue Service is investigating you for tax evasion, or if you have already been charged with a federal tax crime, experienced legal representation can be critical.

Tampa tax evasion defense attorney Michael J. Petro represents individuals, business owners, executives, professionals, and others facing serious federal tax investigations and criminal charges in Tampa and throughout Florida.

With more than 34 years of criminal defense experience, Attorney Petro represents clients at every stage of federal criminal proceedings, from the initial investigation through indictment, trial, sentencing, and appeal.

Federal Tax Evasion Charges

Federal tax evasion is a serious criminal offense. Under 26 U.S.C. § 7201, it is a felony to willfully attempt in any manner to evade or defeat a tax imposed by federal law or the payment of that tax.

Tax evasion cases can involve allegations that a person intentionally concealed income, assets, or financial transactions in an effort to avoid paying taxes legally owed to the United States.

Federal tax investigations may involve allegations concerning:

  • Unreported income
  • Concealed assets
  • False information on tax returns
  • Undisclosed financial accounts
  • Cash transactions
  • Business income
  • Improper deductions
  • False business expenses
  • Transfers of assets
  • Use of nominees or other entities
  • Failure to pay taxes
  • Attempts to conceal financial activity from the IRS

The existence of a tax discrepancy does not by itself establish criminal tax evasion. The government must prove the elements of the charged offense beyond a reasonable doubt.

Willfulness in a Federal Tax Evasion Case

One of the most important issues in many criminal tax cases is willfulness.

Federal tax laws are complicated. People can make mistakes, rely on incorrect professional advice, misunderstand tax obligations, or maintain inaccurate records without intentionally committing a federal crime.

A criminal tax case therefore requires careful consideration of what the defendant knew and intended at the time of the alleged conduct.

A Tampa tax evasion defense attorney can examine the government’s evidence concerning intent, financial transactions, tax filings, communications, professional advice, and other circumstances relevant to whether the government can prove willful conduct.

IRS Criminal Investigations

Criminal tax investigations may be conducted by IRS Criminal Investigation, the law enforcement division of the Internal Revenue Service.

An investigation can begin before the person under scrutiny realizes that federal agents are examining his or her financial activity.

Investigators may review tax returns, bank records, business records, accounting information, electronic communications, and other financial evidence. They may also interview employees, accountants, business associates, family members, and other potential witnesses.

If IRS criminal investigators contact you for an interview, consider obtaining legal advice before answering substantive questions.

Statements made during an investigation can become evidence in a later criminal prosecution.

What to Do if IRS Criminal Investigation Contacts You

If federal agents contact you regarding a potential criminal tax matter, you have constitutional rights.

You generally have the right to remain silent and the right to consult an attorney. Exercising those rights should not be confused with refusing to cooperate unlawfully.

Before providing a statement, producing records voluntarily, or attempting to explain financial transactions, it can be important to understand the nature of the investigation and your potential exposure.

Attorney Petro can communicate with investigators and federal prosecutors on your behalf, evaluate the allegations, and begin developing an appropriate defense strategy.

Grand Jury Subpoenas in Federal Tax Investigations

Federal tax investigations may involve grand jury subpoenas seeking financial and business records.

A subpoena may request:

  • Bank statements
  • Tax returns
  • Accounting records
  • Business records
  • Emails
  • Text messages
  • Contracts
  • Corporate documents
  • Financial transaction records
  • Electronic files

Receiving a federal grand jury subpoena does not necessarily mean that you will be charged with a crime. However, the subpoena should be taken seriously.

Counsel can review the subpoena, determine what information must be preserved and produced, evaluate potential privilege issues, communicate with federal prosecutors, and assess the recipient’s position in the investigation.

Defending Against Federal Tax Evasion Allegations

There is no single defense strategy that applies to every federal tax case.

An effective defense requires careful examination of the government’s allegations, financial evidence, tax records, witness testimony, and evidence concerning the defendant’s intent.

Depending on the circumstances, important issues may include whether the government can prove willfulness, whether an alleged tax deficiency exists, whether financial transactions have an innocent explanation, whether the defendant relied on accountants or other professionals, and whether the government can establish the charged conduct beyond a reasonable doubt.

Attorney Petro carefully reviews the evidence and applicable federal law to develop a defense strategy based on the individual circumstances of each case.

How a Tampa Tax Evasion Defense Attorney Can Help

Federal tax prosecutions can involve complicated financial evidence and substantial investigative resources.

Attorney Petro’s representation may include:

  • Communicating with IRS criminal investigators
  • Communicating with federal prosecutors
  • Evaluating the government’s allegations
  • Reviewing tax and financial records
  • Responding to grand jury subpoenas
  • Investigating the government’s evidence
  • Examining evidence concerning willfulness
  • Evaluating searches and seizures
  • Filing appropriate pretrial motions
  • Challenging the admissibility of evidence
  • Negotiating with federal prosecutors
  • Preparing the case for trial
  • Advocating at federal sentencing
  • Pursuing appropriate federal appeals

Early representation may provide opportunities that are no longer available after charges have been filed. If you learn that you are under investigation, obtaining legal advice promptly can help you understand your rights and make informed decisions about how to respond.

Experienced Federal Tax Crime Representation in Tampa

Being investigated for tax evasion does not mean that you are guilty of a federal crime. An indictment is an accusation, and the government bears the burden of proving guilt beyond a reasonable doubt.

Michael J. Petro provides experienced federal criminal defense representation to clients facing tax evasion investigations and other serious federal tax allegations.

If IRS criminal investigators have contacted you, you have received a federal grand jury subpoena, or you have been charged with tax evasion, consulting an experienced Tampa tax evasion defense attorney can help you understand the allegations, your rights, and the defense strategies available to you.

Contact Michael J. Petro to discuss your federal tax investigation or criminal case.