IRS Audits & Investigations

Angeli & Calfo represents clients in proceedings involving alleged violations of federal, state and local tax laws. Our attorneys have represented companies and individuals in criminal tax investigations involving allegations of tax evasion, preparation of false tax returns, failure to file returns, and conspiracy to impede and impair the IRS. We have also represented numerous clients in connection with asset forfeiture proceedings.

Representative Cases

• Represented a client accused of engaging in a $200 million tax fraud scheme, in a case described by the U.S. Department of Justice as “by far the largest criminal tax case in the history of Oregon.” After five years of investigation and litigation, including a contested sentencing hearing in which the government sought a substantial prison sentence, secured a sentence of probation without any prison time, fine, or restitution requirement imposed on the client.
• Represented a senior executive of an Asian corporation in connection with an investigation into alleged tax fraud relating to the granting of stock options and other deferred compensation. No criminal or civil enforcement action was filed.
• Represented an executive in connection with a federal criminal prosecution and private class action lawsuit involving a complex multi-industry investment program offering significant tax benefits to its investors. No criminal or civil enforcement action was filed against the executive.
• Represented the owner of a group of clubs in the adult entertainment industry in connection with a federal criminal tax investigation. No criminal or civil enforcement action was filed against the individual or the clubs.