If the IRS Criminal Investigation division contacts you, stop talking. Don't answer questions. Don't provide documents. Call a tax attorney immediately. This is not a collections issue. This is a criminal investigation, and everything you say can be used against you.
When It Becomes Criminal
Tax fraud. Willful evasion. Filing false returns. Failure to file with intent to evade. Structuring bank transactions. These are federal crimes carrying prison time. Treat any contact from IRS Criminal Investigation as serious.
Attorney-Client Privilege
This is where privilege matters most. The practitioner privilege under IRC 7525 that covers CPAs and enrolled agents does not apply in criminal matters. Attorney-client privilege does. If there's any possibility of criminal exposure, you need a lawyer. Period.
The Investigation Process
CI agents gather evidence before you even know you're being investigated. They interview witnesses, review bank records, and build their case. By the time they contact you, they already have significant evidence. Your response from that point forward is critical.
Voluntary Disclosure
If you come forward before the IRS initiates an investigation, you may be able to avoid criminal prosecution through voluntary disclosure. Timing is everything. Once an investigation starts, this option closes.