Boston area tax law attorney Theodore L. Craft represents clients in highly sensitive tax inquiries, investigations, proceedings and special programs. Although most tax issues arise primarily through IRS tax audits, they also arise out of IRS compliance enforcement efforts against those who have not filed tax returns or those who have filed returns which have not reported income. One example of this is the Offshore Voluntary Disclosure and Streamlined Offshore Disclosure Programs. Moreover, the IRS may conduct criminal investigations administratively or through a grand jury investigation. Having experienced legal counsel on your side is essential when confronting serious tax matters.
Dedicated Defense Against Tax Abuse Allegations
The IRS may attack transactions reported on tax returns for many reasons. For example, it may deny tax benefits claimed in relation to what it considers sham transactions, which are transactions entered into solely for a tax advantage. These transactions lack economic substance. IRS may also challenge "distributions" to business owners by their businesses in the form of constructive dividends. These can be charge card or other purchases by corporate owners which are inherently for personal as opposed to business use, the use of business assets or income for the personal, undeclared benefit of a business owner.
Settlements on terms favorable to clients in all tax cases require experience based negotiation skills and extensive procedural knowledge of the particular area involved. With his extensive government and private practice experience, Attorney Ted Craft provides a valuable legal service in multiple areas of taxation. The viability of a client's evidence and of allegations or findings of the IRS are not always at odds. There are many cases which resolve quickly, especially where the client is prepared to produce corroborative evidence and have patience through the process.
Protecting the Rights of Individuals in Criminal Tax Matters
In addition to handling economic substance and constructive dividend cases, Mr. Craft also defends against criminal tax violations, as well as IRS tax abuse allegations and other tax controversies. He is skilled in negotiating settlements of offshore account disputes as well, having handled dozens of OVDI cases since the special offshore program involving United States taxpayers who had accounts at UBS in Switzerland was initiated in 2009. Currently, tax attorney Craft is handling many new Offshore Voluntary Disclosure Program cases, including those especially suited to the new program offering streamlined offshore compliance.
Experienced Legal Representation in Tax Matters
Attorney Craft has over 40 years of experience in tax law and procedure. He worked at IRS Chief Counsel's Office in Washington, D.C. making litigation and policy decisions and was trained by the Department of Justice Tax Division, Criminal Section to prosecute criminal tax cases. He has resolved hundreds of tax cases with the IRS and the Department of Justice. He works with the IRS Regional Appeals Division to achieve administrative settlements. He brings civil cases to settlement or trial in the United States Tax Court. He defends clients in federal and state criminal tax prosecutions from inception to plea or trial and at sentencing hearings. He has also taken many appeals to the United States Court of Appeals for the First Circuit.
It is important to note that Certified Public Accountants (CPAs) are not versed in the nuances of tax law. In order to truly be effective in a tax controversy one must have experience with the rules of evidence and various courtroom techniques. That is why you can confide in Mr. Craft for the most demanding tax representation — audits, summons enforcement, civil appeals, criminal investigation defense, defense during prosecution of a criminal tax offense and offshore disclosure proceedings. He brings effective representation to the table.
Contact an Attorney for Help With IRS Tax Audits and Other Tax Controversies
If you are facing a federal tax audit or other challenge please Contact a tax law lawyer online or call 1-888-TAX-RISK [1-888-829-7475] directly to express your concerns and, if necessary, schedule a consultation to work towards a resolution of your matter. The office is in Melrose, Massachusetts, and is easily accessible from both Routes 95 or 93. Get the skilled legal representation you need.