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Parallel Proceedings

Guiding Taxpayers in Parallel Proceedings

In certain situations a taxpayer may find himself subject to a parallel proceeding.  A parallel proceeding occurs when an individual or business entity is under criminal investigation while, simultaneously, undergoing an IRS civil audit.  Parallel proceedings are particularly dangerous for the taxpayer.  While the criminal and civil proceedings are technically two separate investigations, information uncovered by the IRS civil division in the course of an audit can be used by the IRS Criminal Investigation (CI) Division in its criminal investigation.  Parallel proceedings can also involve two different federal agencies.  For instance, the IRS may be examining the taxpayer in connection with a fraud investigation and unbeknown to the taxpayer, the agency may share information with other federal agencies.

While the IRS cannot conduct a criminal investigation under the guise of a civil investigation, the IRS ordinarily does not have an affirmative duty to inform the taxpayer of the existence of a criminal investigation.  Additionally, when the IRS CI Division initiates a criminal investigation of a taxpayer, the civil division is not required to terminate the civil audit.  Since there is a real risk that information gathered during the civil audit process may be used for a criminal investigation, taxpayers undergoing an IRS civil audit should consult with an experienced tax law firm.  A skilled tax law attorney will have a full understanding of the policies and procedures governing IRS parallel proceedings and can carefully guide you through each step of the civil and criminal investigation processes. 

A Skilled Virginia Criminal Tax Lawyer Can Help You Face a Parallel Proceeding

If you find yourself facing parallel civil and criminal proceedings Thorn Law Group can help.  We are a skilled tax law firm with years of experience guiding clients through IRS civil audits and criminal investigations.  Many of our attorneys have worked as IRS trial lawyers and we use this special insight and knowledge to represent individuals, corporations, partnerships and other entities in complex and sophisticated tax law disputes.  When the stakes are high, clients in Virginia and around the nation turn to our firm to provide the support and advice they need to successfully settle their most challenging tax law issues.  

At Thorn Law Group we understand just how much can be at risk when a client is targeted for a civil audit.  While the IRS agent conducting a civil audit may not be obligated to disclose that a taxpayer is under criminal investigation, our attorneys are well aware of the various IRS actions indicating that the government is working to build a criminal case.  Our lawyers carefully analyze how the audit is being conducted and work to protect our clients’ legal rights at every stage of the process.  We have a keen awareness of the rules and procedures governing IRS audits and parallel proceedings and will take swift action when we suspect that the government may be exceeding its authority. 

Discuss Your Situation with Our Tax Law Team

With the IRS and other federal agencies expanding the use of parallel investigations, it is critical for taxpayers to consult with legal counsel when they discover that they are being audited by the IRS.  A knowledgeable tax law attorney can provide you with the information and legal advice you will need to deal with a very challenging and risky situation. 

If you have questions about an IRS audit or think that the government may initiate parallel proceedings against you, contact Kevin E. Thorn, Managing Partner of Thorn Law Group immediately. Consultations with our firm are confidential and we can be reached in our Virginia offices by calling 703-752-3752 or emailing ket@thornlawgroup.com.

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