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EXPERIENCE YOU CAN DEPEND ONRESOLVING COMPLEX TAX PROBLEMS

A Senior Trial Lawyer in the IRS Office of the Chief Counsel for 12 years and has since defended private
and public businesses and high-profile individuals for over 25 years in civil and criminal tax matters.

Experienced Boston Area Tax Law Lawyer

Settlements on terms favorable to you 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 evidence available to you and of allegations or findings of the IRS is not always at odds. There are many cases that resolve quickly, especially where an individual is prepared to produce corroborative evidence and have patience through the process.

Attorney Craft worked at the 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. His experience includes:

  • Resolving hundreds of tax cases with the IRS and the Department of Justice
  • Working with the IRS Regional Appeals Division to achieve administrative settlements
  • Bringing civil cases to settlement or trial in the United States Tax Court
  • Defending client interests in federal and state criminal tax prosecutions from inception to plea or trial and at sentencing hearings
  • Taking numerous appeals to the United States Court of Appeals for the First Circuit
Theodore L. Craft, Esq.

Dedicated Defense Against Tax Abuse Allegations

Our representation brings clinical composure and firm advocacy to the process of framing evidence in the best possible light for the client. An IRS audit or even a criminal investigation is always a civil matter until it is not. Where a potential for referral by the IRS to the Department of Justice for initiation of criminal prosecution is presented, we strive through implementation of defensive strategies to limit it. Where evidence of criminal intent overwhelmingly favors the government, we strive toward mitigation of the potential for hardship otherwise faced through negotiation of favorable plea agreements and arguments further to mitigation at sentencing hearings.

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. The 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.

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, Mr. Craft is handling many new Offshore Voluntary Disclosure Program cases, including those especially suited to the new program offering streamlined offshore compliance.

Contact Theodore L. Craft for a consultation about your case.

Knowledgeable Legal Representation In Tax Matters

It is important to note that although certified public accountants (CPAs) may be versed in the nuances of presenting records as evidence of transactions in general audit matters, they are not generally well-versed in matters in which there is an indication that fraud allegations may surface from an examination of books and records. In order to truly be effective in such a tax examination, one must have a depth of experience not only with an IRS procedural review for such issues but also possess a deep grasp of the rules of evidence as applied to "affirmative acts," "willful blindness," "constructive dividends" and similar concepts.

Effectively presenting a client's case evidence through such an examination is a matter of experience. 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.

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, call 888-TAX-RISK or 800-481-8209 to schedule a free consultation to work toward a resolution of your matter. We represent clients throughout Greater Boston. Our office is in Melrose, Massachusetts, and is easily accessible from both routes 95 or 93. Get the skilled legal representation you need.

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Theodore L. Craft Esq., LLMAttorney at Law & Tax Counsel

49 Myrtle Street | Melrose, MA 02176 | Toll Free: 888-TAX-RISK | Melrose Law Office Map