Amended Tax Returns
With any tax case, we work with the taxpayers to make sure tax returns are correct. If tax returns are not correct, depending on the facts and circumstances, we discuss filing amended tax returns with the client.
There are sometimes joint criminal and civil federal tax and state tax investigations, but usually criminal tax investigations take precedence for a variety of reasons. Sometimes criminal federal tax investigations involve multiple agencies, such as the Internal Revenue Service, Federal Bureau of Investigation, etc. Sometimes after federal or criminal tax investigations and/or prosecutions, there are civil federal tax and state tax audits or other activities.
We provide representation regarding the economics of contemplated transactions, including ensuring that clients are aware of tax consequences that may arise, including in the future, in regard to transactions. We have experience in handling the sales of businesses, real estate investments, commercial properties, professional practices, etc.
Trust Officer Embezzling From Financial Institution
We represented a long-time employee of a major financial institution located in St. Louis. She was a trust officer. The trust officer withdrew funds from a depositor's account and placed the funds in her own account which she opened at the same financial institution. The money never left the bank. When the fraud was discovered, restitution by the trust officer was made. The bank was made whole. The depositor was made whole. However, the client had substantial unreported income during the year of embezzlement. Since the monies were repaid the following year, there was no deduction or offset available to the client for tax purposes. That meant that even though the client repaid all of the unreported income, but in a subsequent year, there was substantial tax, penalties, and interest owed by the client for the year of embezzlement.
Fictitious Dental Lab
Pursuant to a scheme, payments were made by the dental practices to a dental lab. The problem was the dental lab did not exist. The dentists and their accountant were investigated for criminal tax fraud. The dentists claimed that they were following the advice of their accountant.
Hairdresser Not Reporting Income
We represented a hairdresser that had businesses in several cities. Based on the lifestyle and expenditures of the hairdresser, including trips, luxury automobiles, etc., the Internal Revenue Service was able to show, by an indirect method of proof, that expenditures were exceeding reported income.
Representation of an Attorney Regarding Tax Evasion
We represented a city attorney in Southern Illinois who was involved in a scheme whereby out-of-state truckers on an interstate highway were ticketed. They were allowed not to return to the area with a disposition of their case that included a fine and costs. The problem was that the city attorney was funneling the amounts received into a separate account, and not for the city. In other words, the tickets were being dismissed, the amounts were paid by the truckers but the amounts paid were not being received by the city. The attorney was charged with filing false tax returns because he did not report the income that he wrongfully received from the scheme.
Illinois Department of Revenue Criminal Tax Case Against Insurance Agent
We represented an insurance agent in Southern Illinois that was charged with not filing tax returns and/or filing false tax returns with the State of Illinois. The insurance agent was a person of high standing and repute in his community. He was a good family man, attended church regularly and was active civically in his town. However, without any justifiable reason, he simply chose to stop filing tax returns. By the time he was investigated by Special Agents with the Illinois Department of Revenue, psychological and psychiatric defenses were considered, since the client had no prior criminal record and was a successful business person of considerable substance and wealth.
Church Pastor Did Not Pay Taxes
We represented the pastor of a religious organization in regard to not paying taxes on his salary earned serving his congregation. There was concern regarding how it may look to the parishioners if their pastor was having his salary levied by the Internal Revenue Service. We were able to work with the pastor, and the Internal Revenue Service, and avoid any criminal action, as well as avoid any negative publicity and the pastor was able to maintain his reputation with the congregation.
Internal Revenue Service
We have been representing clients before the Internal Revenue Service for years. This type of work can include taxes, penalties and interest, clients that have not filed tax returns for years, including strategies relating to criminal and civil, working on Offers in Compromise with respect to liability and collectability, installment payment arrangements and other matters. We also represent clients at audits, including at our offices, or the client's place of business, or at the Internal Revenue Service offices.
Illinois Department of Revenue
We have been representing clients for years with respect to the Illinois Department of Revenue. Those matters could include sales tax, use tax, income tax, state tax, persons or businesses that have not timely filed all tax returns, persons or businesses that are being audited, persons or businesses that do not have sufficient funds to pay.