P - Pissetzky Law

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P - Pissetzky Law
312-239-8292 | Se Habla Español.
Our Team Is Always In Your Corner

Federal Defense For Accountants, Certified Public Accountants And Tax Preparers

When the IRS Criminal Investigation (IRS-CI) division targets your practice, agents are not searching for simple clerical errors. They are building a federal case to revoke your license, close your business and secure a prison sentence. The federal government relies on sophisticated algorithms and data metrics to catch tax professionals. At Pissetzky Law LLC, our legal defense strategy focuses on dissecting government data streams and aggressively defending your practice from day one.

We offer comprehensive legal defense services for certified public accountants, independent tax preparers, corporate financial officers and tax firm executives. Attorney Gal Pissetzky brings over two decades of federal trial experience inside the Everett M. Dirksen U.S. Courthouse. When federal agents issue target letters, execute search warrants or convene grand juries, he systematically challenges the government’s data assumptions to vigorously defend your liberty.

The Legal Threat Of 26 U.S.C. § 7206(2)

Federal prosecutors frequently leverage 26 U.S.C. § 7206(2) against financial professionals. Under this statute, aiding, assisting or advising in the preparation of a fraudulent tax document is a severe federal felony.

The law holds professionals criminally liable for advice and return entries, entirely independent of the taxpayer’s own liability. Individuals can face lengthy prison terms and substantial fines even if the client was unaware of the inaccuracies.

Pattern-Driven IRS Investigations

IRS-CI rarely initiates an investigation based on a single return. Instead, automated agency software scans thousands of filings across an entire client base to isolate statistical anomalies:

  • Schedule C deductions: Algorithms flag repetitive, high-volume business expense claims.
  • Tax credits: Automated sweeps highlight recurring or questionable Earned Income Tax Credit (EITC) filings.

Once an algorithm detects a pattern, federal agents deploy structured sting operations, send undercover operatives into target offices or execute search warrants for broad data sweeps.

Good Faith And Reliance Defenses

Tax professionals are financial experts, not private investigators. Practitioners must routinely rely on the documentation provided by their clients.

Our legal team crafts robust “good faith reliance” defenses designed to demonstrate that you acted strictly on information supplied by deceptive clients. By exposing client misrepresentations, fabricated receipts and false statements, our attorneys work to dismantle the prosecution’s claim that you willfully committed tax fraud.

Collateral Professional Consequences

A federal criminal investigation threatens a career long before a case ever reaches a courtroom. The government can move swiftly to suspend electronic filing privileges, revoke Preparer Tax Identification Numbers (PTINs) and notify state licensing boards. Our attorneys intervene quickly, seeking to mitigate pretrial administrative actions before they harm your firm.

Frequently Asked Questions

Q: What if a client lied to me, but the IRS is blaming my business?

A: This is the most critical battleground in your defense. To convict you, the government must prove you acted willfully – meaning you knew the numbers were fake and intentionally broke the law. If a dishonest client handed you fabricated spreadsheets, altered receipts, or lied about their revenue, you are a victim of their fraud, not a co-conspirator. We immediately audit your intake logs, questionnaires, and emails to prove you acted in good faith based on the data you were provided.

Q: Can the IRS freeze my accounts or shut down my firm before I’m indicted?

A: Yes. If IRS agents secure a federal injunction or forfeiture order, they can lock your corporate bank accounts, seize your computers, and revoke your electronic filing privileges during an active investigation. Because this can bankrupt a firm before trial even starts, we move instantly to challenge overbroad search warrants, protect your data, and fight administrative seizures so your business survives the investigation.

Contact Us To Protect Your Practice And Freedom

If you have received an IRS-CI target letter, a grand jury subpoena or an administrative search warrant, do not wait for the Department of Justice to issue an indictment. Contact us at 312-239-8292 or send us an email today to begin building your defense.