Tax Controversy and Tax Fraud (Civil or Criminal Defense)

Sequence Inc. provides expert assistance in resolving both civil and criminal tax matters. Tax cases are very often based upon complex assumptions made by taxing authorities regarding a taxpayer’s income and expenses. Those assumptions are many times made without a full analysis of all available data, but the burden of proof rests with the taxpayer. Many times the cases involve large quantities of financial documents that need a thorough analysis.

The taxpayer is generally at a disadvantage in tax matters due to to the lack of expertise regarding financial documentation, estimation methods, and tax law. Sequence Inc. has the experience required to effectively challenge the taxing authorities on their calculations and proof of income and expenses.

As a graduate of the Federal Law Enforcement Training Center’s Criminal Investigator Training Program, Tracy Coenen has training and experience with financial analysis methods utilized by federal and state taxing authorities for both civil and criminal tax matters.

Services Provided

Sequence Inc. can analyze the government’s case theory and point out the strengths and weaknesses in the case. Specific assistance provided may include:

  • Completion of a financial analysis early on to determine risks in the case
  • Organization of accounting information and evidence
  • Reconstruction of financial documentation to determine income and expenses
  • Assistance with the development of technical defenses
  • Analysis of calculations and methods used by the government
  • Application of direct and indirect methods of calculating income, including lifestyle analysis, net worth analysis, bank deposit analysis, and source and application analysis
  • Assistance with interpreting and applying the tax code to specific income and expense items (often to rebut the interpretation and application suggested by the government)
  • Expert witness testimony
  • Calculation of the tax loss to assist in sentencing

Our examination will be conducted to best address issues being pursued by the government. We review calculations and assertions made by the taxing authorities, render an opinion, and if necessary, provide evidence to challenge the government’s position. Alternatively, we have the ability to conduct an independent examination of available documentation to calculate items in question for accuracy and correct application.

To discuss your case via telephone or to arrange for a consultation

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