CRIMINAL TAX DEFENSE

Represented clients during IRS’s criminal investigation of omitted income in excess of $3 million.  Both clients received a probationary sentence despite a Sentencing Guideline range of 30-37 months’ incarceration and U.S. Probation and the U.S. Attorney’s request for 24 months’ incarceration.

Represented two UBS account-holders who collectively held $6 million in offshore accounts through foreign corporations, and received probationary sentences and no prison time.

Represented client who was indicted for holding $4 million in an offshore account; client received probationary sentence and no prison time.

Represented real estate developer in IRS criminal investigation and persuaded the Department of Justice Tax Division not to indict or prosecute because case involved complex partnership tax issues and should not be pursued.

Persuaded Department of Labor to close its criminal investigation of trustees (physician owners of a medical practice) who failed to pay to the plan the employees’ 401(k) contributions that were withheld from the employees’ paychecks.

Served as co-counsel for defendant tax shelter promoter in largest tax evasion case ever brought in Western Washington.

Represented individual in tax evasion prosecution involving the use of sham transactions to obtain cash from the client’s corporations tax-free; client received probationary sentence and no prison time.