Annapolis Tax Fraud and Criminal Defense Lawyer

Trial-tested tax fraud and criminal defense representation for individuals and businesses facing federal and state investigation.

If you have learned that your tax matters are under criminal review, that you are the subject of a grand jury subpoena, or that the IRS Criminal Investigation Division has reached out to you, the situation is serious and the timing of counsel matters. At Crepeau Mourges, our Annapolis, MD tax lawyer practice represents individuals, business owners, professionals, and tax preparers in federal and state tax fraud investigations and prosecutions. Founding partner Brandon N. Mourges is board-certified in Tax Law by The Florida Bar and previously served as a partner focusing on tax controversy and criminal defense. Founding partner Brian J. Crepeau is a tax attorney, Certified Public Accountant, and Certified Fraud Examiner. We invite you to schedule a complimentary case review.

Tax Fraud and Criminal Defense Lawyer Annapolis, MD

Tax fraud refers to the intentional violation of federal or state tax laws. The conduct typically involves the willful underreporting of income, the overstatement of deductions, the failure to file returns, the failure to pay tax, or the preparation of false returns for others. Civil tax law uses the same factual record but applies a different standard, and many matters that begin as civil examinations are referred to criminal investigators when certain indicators appear.

The transition from civil to criminal is rarely announced. A taxpayer often learns of the change through a contact from a Special Agent with the IRS Criminal Investigation Division, through a grand jury subpoena, or through inquiries directed at family members, employees, or business associates. Earlier tax controversy and disputes representation is sometimes the first signal that a matter is moving in this direction. A tax fraud and criminal defense lawyer in Annapolis assists clients in responding appropriately at each phase of the investigation.

Types of Tax Fraud and Criminal Defense Cases We Handle in Annapolis

Tax fraud and criminal defense matters arise in a variety of contexts, and our Annapolis tax attorneys represent clients across that range. Some matters involve individual taxpayers. Others involve businesses, tax preparers, or professionals whose financial conduct is under review.

• IRS Criminal Investigation Division contacts. The unannounced arrival of a Special Agent at a home or business signals a serious change in the posture of a tax matter. We advise clients on responding to these contacts and on the conduct of any subsequent interviews. Useful background on how investigations begin is available on the firm’s blog.
• Willful failure to file and failure to pay. Repeated nonfiling or nonpayment of tax may give rise to criminal charges in addition to civil exposure. We represent individuals and business owners in matters involving allegations of willful conduct surrounding unfiled returns or unpaid balances.
• False return allegations. The preparation or signing of a return that is false in a material respect may give rise to criminal prosecution. We represent individuals and businesses in matters involving alleged misstatement of income, deductions, credits, or other return positions.
• Tax preparer investigations and prosecutions. Return preparers face significant exposure when returns prepared for clients are alleged to be fraudulent. We represent preparers in civil injunction matters and in criminal proceedings arising from their professional practice.
• Employment tax and payroll fraud allegations. Allegations involving the diversion of withheld employment taxes are pursued aggressively by the Internal Revenue Service and the Department of Justice. These matters frequently arise alongside business taxation issues and Trust Fund Recovery Penalty proceedings.
• Structuring and money laundering charges. Cash-based businesses and professionals are sometimes accused of structuring deposits to avoid reporting thresholds or of laundering proceeds through related entities. These matters often involve forfeiture proceedings in addition to substantive criminal charges.
• Offshore account and international reporting investigations. Investigations involving unreported foreign accounts, foreign income, and information returns require both technical international tax knowledge and criminal defense experience.
• State criminal tax matters. The Maryland Attorney General and the Comptroller of Maryland pursue criminal cases involving Maryland income, sales, and other state taxes. We represent individuals and businesses in these matters.
• Internal investigations and corporate cooperation. Companies that discover potential tax fraud within their operations face decisions regarding internal investigation, voluntary disclosure, and cooperation with authorities. We advise on each of these issues with the goal of mitigating organizational exposure.
• Sentencing and post-conviction matters. In matters that proceed to plea or verdict, the sentencing phase carries substantial weight. We participate in sentencing preparation, including advocacy on advisory Guidelines calculations, variance arguments, and conditions of supervision.

Why Choose Crepeau Mourges for Tax Fraud and Criminal Defense in Annapolis, MD?

At Crepeau Mourges, tax fraud and criminal defense work is approached from both a technical tax perspective and a litigation perspective. Many of these matters turn as much on the precise tax issue as on the broader criminal framework, and the firm’s background allows both dimensions to be addressed within a single representation.

Background in Criminal Tax Defense and Internal Investigations

Brandon N. Mourges previously served as a partner at a Baltimore-based firm focusing on tax controversy and criminal defense before establishing Crepeau Mourges. He has represented clients in negotiations resolving criminal tax exposure, including matters involving alleged false returns, structuring, and false statements. Mr. Mourges has also led and participated in internal investigations for closely held businesses, publicly traded entities, and non-profit organizations. He holds an LL.M. in Taxation from the University of Baltimore School of Law, is board-certified in Tax Law by The Florida Bar, and is admitted to practice in Maryland, Florida, Pennsylvania, Virginia, the District of Columbia, the United States Tax Court, the United States Court of Federal Claims, and the United States District Court for the District of Maryland.

Forensic and Accounting Perspective on Criminal Tax Allegations

Brian J. Crepeau brings the perspective of a tax attorney, Certified Public Accountant, and Certified Fraud Examiner with the Association of Certified Fraud Examiners. His background supports the income analysis, recordkeeping reconstruction, and forensic financial review that frequently accompany federal criminal tax matters. He earned his Juris Doctor at American University, Washington College of Law. Mr. Mourges has been recognized as a Rising Star by Super Lawyers and on Benchmark Litigation’s “40 & Under Hot List.” Our work as Annapolis tax lawyers extends across the full life cycle of a criminal tax matter, from the first investigative contact through resolution.

Understanding Tax Fraud and Criminal Defense Cases

Potential Charges, Penalties, and Procedural Posture

A tax fraud and criminal defense matter typically involves several interrelated elements: the potential charges under federal or state law, the associated penalties on conviction or settlement, and the procedural posture of the investigation at the point counsel is retained. These elements often shift across the life of the matter. An investigation that begins as a routine civil examination may transition to a criminal referral and then back to a civil resolution. A representative engagement may address the following:

• The charges under consideration, which may include tax evasion, filing a false return, willful failure to file, conspiracy, money laundering, or related offenses
• The civil tax exposure that exists alongside any criminal matter, including civil fraud penalties and statutory interest
• The collateral consequences of conviction, including professional licensure, immigration status, and forfeiture
• The procedural posture of the investigation, including whether the matter is in the investigation phase, the indictment phase, the pre-trial phase, or the sentencing phase
• The roles of any cooperating parties, witnesses, or co-defendants

Each of these elements affects the others. The procedural posture influences the available negotiation pathways. The collateral consequences influence acceptable resolutions. The civil exposure influences whether civil settlements may proceed in parallel with the criminal matter.

What Are Some Important Aspects in Your Tax Fraud Case?

Several considerations consistently influence the resolution of a criminal tax matter. Each warrants close evaluation early in the engagement.

• The nature of the underlying conduct, including whether the matter involves a single transaction, a pattern of conduct over multiple years, or the actions of multiple individuals
• The quality of the financial records and any contemporaneous documentation
• The taxpayer’s interaction with the Internal Revenue Service or other authorities prior to retaining counsel
• The civil tax liability that exists alongside the criminal matter
• The personal, professional, and financial considerations that may affect acceptable outcomes

We address each of these considerations during the initial consultation. The goal is to provide a candid and accurate assessment of the matter before any substantive engagement with the Internal Revenue Service or Department of Justice.

Tax Fraud and Criminal Defense Case Timeline

Criminal tax matters generally follow a longer course than civil tax matters. The duration depends substantially on the nature of the investigation, the involvement of multiple agencies, and whether the matter proceeds to indictment.

• Initial consultation and review of the known investigative activity
• Document review, including financial records, prior returns, and any correspondence with investigators
• Engagement with the Internal Revenue Service, the Department of Justice, the United States Attorney’s Office, or relevant state authorities
• Negotiation regarding charging decisions and any pre-indictment resolution
• Pre-trial litigation, trial preparation, or plea negotiation as applicable
• Sentencing advocacy in any matter resulting in a plea or verdict

A criminal investigation may extend over two or more years prior to any charging decision. We pace the representation accordingly and coordinate with any prior counsel, accountants, or other professionals where appropriate.

What Should You Bring to Your Tax Fraud and Criminal Defense Consultation?

Please bring whatever documentation you have available. We will identify any additional materials required during the initial meeting.

• Any subpoenas, target letters, or other written communications received from federal or state investigators
• A general summary of the years and tax matters that appear to be under review
• Copies of the relevant tax returns, if available
• A summary of the business operations, financial accounts, or transactions at issue

Most consultations last approximately one hour. At its conclusion, you will have a clearer understanding of the apparent posture of the investigation, the available options, and the recommended next steps. The case review is provided without charge, and there is no obligation to retain the firm afterward.

Important Maryland Legal Resources for Tax Fraud and Criminal Defense Cases

Federal and Maryland authorities publish information that may assist individuals and businesses in understanding the general framework applicable to criminal tax investigations. Clients working with a tax lawyer in Annapolis on a fraud or criminal matter may find these references useful as starting points, though they do not substitute for legal advice on a specific situation.

• The Internal Revenue Service Criminal Investigation Division publishes information regarding its mission, priorities, and investigative process.
• The United States Department of Justice Tax Division handles criminal tax prosecutions in coordination with the Internal Revenue Service.
• The United States Attorney’s Office for the District of Maryland handles federal criminal prosecutions, including tax matters, within Maryland.
• The United States Sentencing Commission publishes the Federal Sentencing Guidelines and related materials applicable to federal sentencing.
• The Office of the Maryland Attorney General handles certain criminal matters under state law.

These sources are useful as preliminary references. They are not a substitute for case-specific counsel. We consult them regularly in the course of our criminal tax work and recommend them as reliable points of orientation.

Reach Out to Crepeau Mourges to Schedule a Consultation

Criminal tax investigations rarely improve with the passage of time, and the timing of counsel often shapes the available outcomes. Contact us to schedule a complimentary case review with an Annapolis tax attorney who represents individuals and businesses in federal and state tax fraud matters. We will identify the apparent posture of the matter, outline the available pathways, and explain what to expect going forward.