Tax Defense: Civil, Criminal And Federal Grand Jury

At the law office of attorney Michael S. Adelman, each client receives tailored representation from a lawyer with over 46 years of tax controversy experience. Mr. Adelman has a broad range of experience and expertise in tax matters ranging from civil to criminal.

Offshore Voluntary Disclosure (OVDP) evaluations

Mr. Adelman has also become extensively involved in IRS offshore account issues, payment card and foreign entity inquiry letters, and compliance efforts involving banks and foreign jurisdictions or other offshore financial arrangements allegedly for the purpose of avoiding or evading United States Tax obligations, as well as the use of allegedly abusive other tax shelters. To learn more about these evolving investigations, please see:

  • Significant developments regarding offshore accounts, Report of Foreign Bank and Financial Accounts (FBARs) and Form 8938
  • Significant developments regarding eligibility for streamlined procedures, Report of Foreign Bank and Financial Accounts (FBARs), the Foreign Account Tax Compliance Act (FATCA) and (most crucially) Intergovernmental Agreements (IGAs) and the crucial, constantly updated list of Foreign Facilitator Institutions (FFI).

It is vital, if a foreign institution you have been involved with is on the FFI List, that you call 856-330-4035 to speak with Mr. Adelman immediately.

Representation From Audits To Collections

Some of the types of civil cases that Mr. Adelman handles include:

  • IRS tax preparer investigations and alleged violations of Treasury Department circular 230 "Practice Before the IRS"
  • Nonfiling and unfiled tax returns that encompass many years
  • Tax audits and examinations (especially if you are being audited for some years/issues, but are concerned about other years/issues)
  • IRS or state tax collection cases — federal tax liens, wage attachments, levies
  • 100 percent penalty/Trust Fund Recovery Act cases
  • IRS Collection Due Process, CAP Appeals and Taxpayer Advocate Appeals

Privileged Communication With An Attorney

All communications to your attorney are confidential and guided by attorney/client privilege. This privilege does not apply to communications with accountants, enrolled agents and most nonlegally staffed tax resolution companies. Carefully "vet" such advertising-heavy companies.

  • IRS collection, filing and payment delinquency cases: The IRS has issued many FRESH START opportunities and expedited procedural options to give people a chance to "dig out." One or more of these options may be available to you, no matter how many years of unpaid taxes are involved, even for those already the subject of frightening enforced collection action (notices, tax liens, wage attachments, bank levies, etc.).
  • Even if you have not filed tax returns (including Individual Income Tax Forms 1040 and/or Employment Tax Forms 941 and 940) for many years, Mr. Adelman will work with you and an accountant will work with you to help you get into compliance. With experienced guidance, this is fixable.

The IRS knows that thousands of people, many already with significant criminal and/or civil federal tax exposure, really want to become compliant but simply do not know where to begin or how to navigate what often are complex IRS procedures and requirements.

The IRS is inviting such people to trust that if certain leaps of faith are made, a fair resolution will be achieved through a win-win process. A "kinder, gentler" IRS? Not entirely, because there is hard work to be done to qualify for these programs and opportunities, and in most cases there will be a financial (tax) price based on your documented circumstances.

Get Peace Of Mind

Mr. Adelman has found that "at the end of this process, virtually all of my clients assure me that the peace of mind was absolutely worth it." Send an email to schedule a free phone initial consultation to discuss your concerns.

Defense For Federal Tax Crimes

In criminal tax matters, Mr. Adelman can step in to help at the first sign on an investigation. He handles all aspects of federal grand jury cases. Whether a charge or charges of tax evasion, filing false tax returns or money laundering or Currency and Suspicious Transaction Report (STR) compliance, he can mount a tough defense that protects your rights.

  • Tax evasion
  • False tax returns
  • Money laundering, Currency and Suspicious Transaction Report (STR) compliance

A long-distance, mixed-media and/or in-person consultation can be arranged at a highly competitive fee. At the conclusion of this consultation, a cogent game plan and response will be recommended. Beyond the consultation, flexible arrangements based on the precise circumstances and your needs can be implemented.

Rarely will you be rushed into payment of a large retainer. A step-by-step arrangement is usually feasible. In situations like these, a "one size" approach most certainly does not fit all.

Be sure to ask Mr. Adelman about his unique, written post-Consultation "TCA" Interim Retainer Agreement geared to clearly explaining all the terms of the attorney/client(s) relationship in advance, for the benefit and protection of all parties.

Rely On Decades Of Tax Experience

Whether or not you have received notices or have been otherwise contacted by the IRS, please call Mr. Adelman. He will help you through the process of becoming fully compliant, taking steps to resolve all delinquent filings and unpaid tax periods and getting up to date under one of the Fresh Start options or via other avenues if you do not fit the criteria for the IRS' Fresh Start initiative.

What may seem to be an insurmountable problem that grows worse every year is absolutely solvable working as a team guided by Mr. Adelman's decades of tax controversy experience. Call 856-330-4035 or contact our office online today.