When people call about this
What this usually looks like
- Two agents arrived unannounced and asked to talk
- Your accountant was contacted about your file
- An examination went quiet without explanation
- There is unreported income and you want to come forward before they arrive
How it actually works
The part that decides the outcome
The distinction is the whole case. A revenue agent is an auditor whose job is civil adjustment. A revenue officer collects. A special agent is a criminal investigator, and a special agent making contact means the matter is already being evaluated for prosecution rather than for tax.
Silence is not obstruction. Declining to be interviewed until you have representation is ordinary and expected, and the interview that feels most harmless is usually the one that supplies the elements the government would otherwise have to prove.
Voluntary disclosure exists precisely because coming forward first is worth something. It is a narrow door with conditions, and it closes the moment the government’s own inquiry has begun — which makes the timing of the decision more important than its content.
The engagement
How we work a case like this
1. Identify who is asking
Agent type, scope and posture, before any substantive contact happens.
2. Control the contact
Interviews, records and third-party requests handled through this office.
3. Choose the path
Disclosure while the door is open, or defense of the civil case if it has closed.
Related matters
These rarely arrive on their own
Tax problems overlap. The pages below are the ones that most often belong in the same file as this one.
Unfiled & Delinquent Returns
Most criminal exposure in these cases begins with years that were never filed.
Open — Unfiled & Delinquent ReturnsIRS Audits & Appeals
A civil examination that gets referred becomes an investigation, sometimes without notice.
Open — IRS Audits & AppealsPayroll & Trust Fund Taxes
Withheld money that was never remitted attracts criminal scrutiny quickly.
Open — Payroll & Trust Fund TaxesThis page is general information, not advice for a specific situation. Available procedures depend on the actual record and on current law, which changes. Confirm before acting, or ask this office to review your own facts.
