Miami Tax Evasion Attorney

Federal Tax Defense Backed by More Than 20 Years of Trial Experience

Federal tax evasion cases often turn on whether financial conduct shows criminal intent or instead reflects accounting errors, disputed calculations, or incomplete records. At Law Office of Michael Mirer, P.A., former Miami-Dade prosecutor Michael Mirer leads our defense of clients facing state and federal criminal allegations.

An audit, unpaid balance, or inaccurate return isn’t automatically tax evasion. If IRS Criminal Investigation or another federal agency contacts you, preserve relevant records, don’t alter or destroy documents, and avoid answering substantive questions before obtaining legal advice.

Call (800) 798-0243 to discuss a tax evasion allegation or federal investigation with our criminal defense firm.

Federal Tax Evasion Under 26 U.S.C. § 7201

Under 26 U.S.C. § 7201, prosecutors generally must establish more than a tax mistake. The charge requires evidence of an attempt to evade or defeat a tax or its payment.

The government generally must prove three elements:

• Tax Due and Owing: An additional federal tax was legally owed.
• Affirmative Act of Evasion: The accused took an action intended to evade assessment or payment rather than merely failing to act.
• Willfulness: The accused voluntarily and intentionally violated a known legal duty. Negligence, confusion, and bookkeeping mistakes don’t establish willfulness by themselves.

A conviction under Section 7201 carries a maximum of five years in prison. The statute also authorizes a fine of up to $100,000 for an individual or $500,000 for a corporation, subject to the charge and applicable sentencing rules. Related counts may include false tax returns, failure to file, employment tax violations, money laundering, or conspiracy.

How an IRS Criminal Investigation Develops

IRS Criminal Investigation examines suspected violations of the Internal Revenue Code and related financial crimes. An inquiry may begin with information uncovered during an examination or collection proceeding, a tip from the public, or evidence developed by another law enforcement agency.

Investigators may review tax returns, bank activity, business ledgers, accounting materials, communications, and records involving domestic or foreign assets. After analyzing the evidence, IRS Criminal Investigation may discontinue the inquiry or recommend prosecution to the Department of Justice Tax Division or a United States Attorney’s Office.

Conduct That Can Lead to Tax Evasion Allegations

Investigators may scrutinize how a taxpayer reported income, deductions, assets, and other obligations. The relevant facts can differ substantially for individuals, business owners, employers, professionals, return preparers, and people with international financial activity.

Federal scrutiny may involve claims of:

• Underreported cash, professional, or business income
• Inflated deductions, exemptions, or tax credits
• False or altered returns and supporting documents
• Unreported offshore accounts or cryptocurrency transactions
• Failure to withhold or remit employment taxes
• Use of domestic or foreign arrangements to conceal taxable income

Lawful tax avoidance uses permitted methods to reduce a tax obligation. Tax evasion alleges unlawful, willful conduct. Distinguishing between them requires close attention to the records, the disputed tax deficiency, and evidence of what the taxpayer knew and intended.

A Former Prosecutor’s Perspective on Federal Defense

Michael Mirer has more than 20 years of trial experience and has handled more than 100 trials. As a former Miami-Dade Assistant State Attorney, he prosecuted all levels of crime and served in the Career Criminal Robbery Unit. We handle felony and misdemeanor cases in state and federal court.

We develop a personalized strategy based on the investigation’s stage and the evidence involved. That work includes evaluating the prosecution’s case, protecting constitutional rights, maintaining clear communication, and engaging experienced investigators and expert witnesses when appropriate.

Defense Planning for Tax Evasion Cases in Miami

Our review begins with the government’s theory and the documents supporting it. We examine whether the alleged tax deficiency is accurate, whether the conduct qualifies as an affirmative act of evasion, and whether the evidence supports willfulness.

Depending on the case, our evaluation may address:

• The source, completeness, and reliability of financial records
• Statements attributed to the taxpayer or other witnesses
• Searches, seizures, subpoenas, and investigative interviews
• Accounting analysis and competing interpretations of transactions
• Potential constitutional or procedural issues
• False return, conspiracy, money laundering, or other related allegations

The appropriate response also depends on whether the matter involves a civil examination, preliminary criminal inquiry, grand jury investigation, indictment, or pending prosecution. We assess that posture before advising on communications, records, and the next procedural steps.

Get Clarity on a Federal Tax Investigation

Bring us any notices, subpoenas, correspondence, or details about agency contact. We can evaluate the allegations, identify immediate legal concerns, and explain where the matter stands in the federal process.

Law Office of Michael Mirer, P.A. offers a free and confidential consultation to people facing tax evasion allegations, IRS criminal investigations, and related federal charges.

Speak with our tax evasion lawyer in Miami by calling (800) 798-0243 today.