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What We Do

The Tax Division handles or authorizes most civil and criminal litigation that concerns or relates to the internal revenue laws in federal district and appellate courts. Tax Division attorneys seek to secure correct, uniform and fair interpretations of the internal revenue laws and to ensure that uniform standards are applied in criminal tax prosecutions. Tax Division attorneys work closely with the Internal Revenue Service and United States Attorneys' Offices to develop tax administration policies; handle civil trial and appellate litigation in federal and state courts; pursue federal grand jury investigations; and handle criminal prosecutions and appeals. To the greatest extent possible, the Tax Division coordinates the use of both civil and criminal enforcement tools, to maximize the deterrent effect of its litigation and to enhance collection efforts.

Significant recent Tax Division initiatives include the following:

  • Attacking the use of "secret" foreign bank accounts to evade taxes

    • Enforcing IRS summonses for records of offshore credit card transactions

    • Initiating criminal investigations of suspects in offshore tax evasion cases

  • Halting the spread of abusive corporate tax shelters

    • Defending in civil proceedings the IRS’s disallowance of sham tax benefits

    • Prosecuting professionals who knowingly promoted and facilitated illegal tax shelter transactions that defrauded the IRS

  • Investigating and prosecuting individuals and corporations that attempt to commit tax fraud or evasion

  • Combating the tax defier movement

  • Shutting down fraudulent tax return preparers

    • Investigating and prosecuting tax return preparers who willfully prepare false tax returns

    • Seeking civil injunctions to bar fraudulent return preparers from preparing returns

    • Working with IRS to conduct training on gathering evidence about fraudulent return preparers

  • Fighting abusive and fraudulent tax promotions

  • Combating schemes that cheat the IRS through abuse of the bankruptcy system

    • Challenging the discharge where the debtor made a fraudulent return or willfully attempted to evade or defeat the tax

    • Making criminal referrals of suspected bankruptcy fraud

  • Enhancing policy coordination between the Tax Division and the IRS

Updated February 17, 2023