Criminal Tax Litigation

Professional Criminal Tax Representation

Jed is a former federal prosecutor who tried ten white collar criminal cases to verdict as a government lawyer and a defense attorney in federal court. More importantly, Jed has experience ensuring that cases are never brought. Matters for which clients seek Jed’s services include:

Responding to IRS-CI

IRS-CI will frequently approach subjects of criminal investigations both for an interview or documents (by way of a record request called a summons). Jed has experience advising clients on how (or if) they should respond to interview requests as well as responding to summonses. Jed is familiar with the rules pertaining to these summonses and can advise taxpayers on their rights, including their right not to produce information.

Search Warrants

The IRS-CI may search a taxpayer’s home, business or computer. Jed has experience helping taxpayers whose homes have been searched or property has been seized.

Tax Professional Representation

Besides representing taxpayers, Jed has experience counseling tax return preparers responding to requests for information. Tax professionals have legal obligations that mandate what can or cannot be produced in response to summonses, subpoenas and other requests for information. Jed has advised accountants and other tax professionals regarding how to respond to these information requests in both IRS litigation and in general civil litigation.

Criminal Tax Charges

Jed has prosecuted and defended dozens of criminal tax cases and is familiar with charges including tax evasion (26 U.S.C. § 7201) (evasion of assessment and evasion of payment), filing a false income tax return (26 U.S.C. § 7206(1)), willful failure to collect or pay over tax (26 U.S.C. § 7202), aiding and assisting in the preparation of a false return (26 U.S.C. § 7206(2)), willful failure to file a return or pay tax (26 U.S.C. § 7203), delivery of a fraudulent return (26 U.S.C. § 7207), and attempt to influence the administration of the tax laws (26 U.S.C. § 7212(a)).


Individuals with a history of unfiled tax returns may need to come into compliance. Jed counsels clients on the best steps to avoid criminal prosecution and minimize civil penalties.

IRS Voluntary Disclosure

Jed has helped clients, who have substantial criminal exposure, enter the IRS voluntary disclosure program and subsequently file tax returns or amended tax returns.

Federal Sentencing Guidelines

Defendants who plead guilty or are convicted are sentenced under the “T” table of the federal sentencing guidelines. Jed has handled dozens of cases involving the tax federal sentencing guidelines. Jed’s depth of knowledge helps defendants who wish to minimize their criminal exposure.

Collateral Consequences

A federal felony conviction has substantial collateral consequences. A defendant who is convicted faces a term of incarceration. However, criminal tax cases can result in restitution orders, additional Tax Court litigation regarding penalties, and other hardships like foregoing the right to own a weapon or vote, as well as immigration consequences. Jed has experience advising clients in these areas.

Being contacted by IRS-CI is a life altering event. IRS criminal investigations impact not just the individual being targeted but also family members, business partners and others. Even an indictment can cause substantial reputational harm. Jed has the experience to help avoid an indictment as well as helping to navigate these issues to obtain the best possible outcome.