Theodore L. Craft, Esq., LLM, Attorney at Law & Tax Counsel, in Boston, has over 40 years of tax law and procedural experience and the clinical judgment in highly sensitive tax inquiries, investigations and proceedings to go with it. He will be there for you, defending against the potential for harm, with the judgment and ability to make the winning argument on your behalf.
Taxpayer or third party evidence and statements may contain some potential for harm in a tax audit or investigation. IRS inferences of fact, a revenue agent's [or special agent's] inevitable inquiries, document requests and the like put harm in a more clear perspective. What actions, if any, should be taken to prevent such evidence from poisoning the case? We understand that evidence always has a context with both quantitative and qualitative aspects. The firm's principal, Theodore L. Craft, has evaluated and argued positions on evidence in Government [when the IRS was the "Client" in civil and criminal matters in litigation] and for private Clients during his entire career as a tax lawyer. 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 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 towards mitigation of the potential for hardship otherwise faced through negotiation of favorable plea agreements and arguments further to mitigation at sentencing hearings.
The Craft law firm also represents those who choose to participate in the Tax Amnesty known as Offshore Voluntary Disclosure and Streamlined Offshore Voluntary Disclosure Programs ["IRS OVDP"]. Acting on favorable interpretations of facts in evidence and tax procedures we protect the rights of those who face the potential for greater harm in this area with the same resolve not simply to do well but to do good for our Clients.
Contact Theodore L. Craft for a consultation about your case.
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 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 are 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.
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.
Knowledgeable Legal Representation In Tax Matters
Attorney Craft has over 40 years of experience in tax law and procedure. He 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. 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 client interests 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 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 a such a tax examination, one must have a depth of experience not only with 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. 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 , call 888-TAX-RISK or 800-481-8209 to express your concerns and, if necessary, schedule a consultation to work toward 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.