Criminal & Civil Tax Controversy

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Collora LLP represents both corporate and individual clients in a variety of state and federal tax controversy matters.

Our strategic approach helps clients minimize the impact of civil audits or collection activity and, in the extreme case, a criminal tax investigation. Our lawyers understand how the IRS and Massachusetts Department of Revenue work and strive to achieve the best result possible for clients facing civil enforcement actions or criminal investigations. 

Our lawyers work to successfully resolve a variety of issues associated with IRS and Massachusetts Department of Revenue investigations and enforcement actions pertinent to tax matters, including but not limited to the following:

  • Civil Audits
  • Civil Tax Controversy
  • Collection Actions
  • Criminal Tax Investigations
  • Currency Structuring
  • Filing of False Tax Returns
  • Failure to Withhold and Pay Over Employment Tax
  • IRS and DOR Audit Defense
  • Offers In Compromise
  • Offshore Voluntary Disclosure Initiative
  • Preparation of False Tax Returns for Clients
  • Responsible Officer Penalties
  • Offshore Tax Shelters
  • Summons Enforcement
  • Tax Appeals
  • Tax Evasion
  • Tax Return Preparer Penalties
  • Undisclosed Foreign Bank Accounts

Representative Experience

  • Represented international food services company in federal criminal tax probe related to an acquired company. Resolved the matter with no criminal charge against the client, and obtained reimbursement of civil fine and legal expenses from selling shareholders and lawyers of the acquired company, which pleaded guilty.
  • Represented major real estate developer in hearings before the IRS regarding proper expense or depreciation of capital and non-capital items, persuading the examiner that charges of fraudulent misclassification were not appropriate or necessary.
  • Successfully managed grand jury investigations, representing witnesses or companies with potential exposures and ultimately avoiding any criminal indictment or penalty.
  • Represented automotive dealership in criminal tax investigation resulting in no charges.