Tax Defense

Tax Defense & Representation

Civil Tax Matters vs. Criminal Tax Matters

Civil tax matters and criminal tax matters are held to different standards of proof by the Internal Revenue Service (IRS). The principal difference is that criminal tax matters typically involve fraud or willfulness.

Criminal Tax Issues

The lawyers at Dysart Willis are equipped to handle the following criminal tax matters:

• Tax evasion
• Willful failure to file a tax return
• Willful failure to collect or pay over withholding tax
• Aiding and abetting tax fraud
• Preparing false returns
• False withholding statements
• Failure to properly file, withhold, or remit payroll withholdings to the proper taxing authority
• Tax structuring crimes
• Conspiracy to impede or defeat the collection of tax.

Civil Tax Issues

The lawyers at Dysart Willis are equipped to handle the following criminal tax matters:

• Tax Litigation and Tax Controversy: Tax litigation and controversy describes the practice of resolving tax disputes with federal, state, and local tax authorities. Income tax problems, payroll tax problems, excise tax problems, innocent spouse claims, tax penalties, and estate tax problems all fall into this category of civil tax matters.
• Tax Debt: Tax debt refers to any taxes you owe a taxing authority after the deadline for payment. If you forget to pay or file your taxes, make a mistake on your taxes, or the IRS filed a substitute for return and you owe money as a result, you have incurred a tax debt.

Civil Tax Matters: The Risk

If you have an unresolved tax controversy, the longer you wait to take action, the worse the matter is likely to become. For example, if you have incurred a tax debt, the taxing authority can:

• File a tax lien, which can devastate your credit
• Serve a tax levy on your bank account, wages, or brokerage account
• Seize your state income tax to satisfy a federal tax debt
• Impose penalties for failure to file, failure to pay, or failure to make timely tax deposit and charge you interest as long as the tax remains unpaid