⚠️ Federal Tax Prosecutors Don’t Arrest You Until They’ve Already Built the Case.
Months of surveillance. Controlled buys. Financial records. Cooperating witnesses. By the time federal agents put cuffs on you, they’ve been building the case against you long enough to be confident they’ll win. Marin & Murphy defends these cases as Connecticut federal criminal defense attorneys, with Attorney Stefanie A. Murphy admitted to practice in the District of Connecticut (Bar No. 31712).
What makes federal tax charges different isn’t just the sentences — it’s the math. A conspiracy charge pulls everyone connected into the same exposure. And every co-defendant now has an incentive to make their situation better by making yours worse.
You are behind from the moment of arrest. The only question is how fast you close the gap.
Fill out this form now. You speak directly with a Connecticut federal tax defense attorney — not intake, not a paralegal — who will immediately assess your exposure, identify weaknesses in the government’s case, and tell you exactly where you stand.
In federal court, waiting isn’t neutral. It’s losing ground.
In FY2024, the IRS recovered $20.4 million through criminal enforcement actions in Connecticut alone. Six individuals were sentenced for federal tax offenses in D. Conn. that year — a small number that reflects the IRS’s high selectivity, not a lack of activity. Cases that reach the indictment stage almost always result in prosecution. When federal agents are already looking, call (860) 294-4384 for a confidential consultation.
Why Marin & Murphy for Federal Tax Defense in Connecticut
IRS Criminal Investigation builds cases over years with a conviction rate that exceeds 90%. The agents and prosecutors working your case have financial records, bank data, and third-party information you may not know they have. Your defense counsel needs to match that level of preparation from the first conversation — and needs to understand how IRS-CI investigations are built, how the USAO-CT evaluates tax referrals, and how to navigate the pre-indictment phase when intervention is still possible.
Attorney Stefanie A. Murphy is admitted to the United States District Court for the District of Connecticut (Bar No. 31712) and holds simultaneous active federal bar admissions in D. Conn., D. Mass., and D.R.I. — enabling seamless representation across all three Southern New England federal districts. Both Murphy and Attorney Matthew T. Marin are members of the National Association of Criminal Defense Lawyers, the national professional organization for federal criminal defense practitioners.
Federal tax defense demands the ability to challenge forensic financial evidence at every level — to contest the government’s bank deposit analysis, to identify errors in income reconstruction, to challenge how financial records were obtained through summons or subpoena, and to cross-examine IRS-CI forensic accountants on their methodology. Murphy’s practice focuses specifically on this intersection of forensic evidence and criminal defense. As lead editor and contributing author of A Practical Guide to Trying DUI Cases in Rhode Island (2nd Edition 2024, MCLE New England) — the state’s definitive DUI litigation resource — Murphy has published and lectured on forensic evidence reliability, search and seizure doctrine, and pretrial motions practice. That analytical discipline — deconstructing the government’s forensic case element by element — applies directly to challenging the income reconstruction, loss calculations, and financial record acquisition that determine sentencing outcomes in federal tax cases.
Murphy has tried serious felony cases to verdict that most defense attorneys encounter rarely if ever. The Providence Journal reported her role as lead counsel in a murder acquittal — a case involving co-defendants serving life sentences and prosecution by the Rhode Island Attorney General’s Office. Her work in complex post-conviction DNA litigation — representing a defendant who spent decades incarcerated, where she argued newly discovered DNA evidence excluded her client — reflects the investigative sophistication and persistence that federal tax defense demands. Rhode Island Lawyers Weekly has repeatedly quoted both Murphy and Marin as authorities on constitutional criminal procedure. Prior results do not guarantee a similar outcome. The cases referenced above are described to illustrate the nature of Attorney Murphy’s trial and post-conviction practice. Every case is evaluated on its individual facts, applicable law, jurisdiction, and procedural posture. Post-conviction matters described as ongoing remain in active litigation, and no outcome has been adjudicated.
Attorney Matthew T. Marin has established constitutional precedent that directly informs federal defense strategy. In State v. Corcoran (2022), Marin secured suppression of incriminating statements at the trial court level in a case that resulted in a Rhode Island Supreme Court ruling establishing statewide Miranda precedent. In State v. Zimmerman (2015), Marin originated the constitutional challenge that forced the Rhode Island Attorney General’s Office to revise the DUI rights form used in every arrest statewide. Rhode Island Lawyers Weekly has published six standalone editorial features on Marin’s cases across four consecutive years. His background in complex civil litigation — including PFAS environmental mass tort matters and multi-front proceedings involving federal agencies — directly informs the multi-track approach that federal tax defense requires, where criminal prosecution, IRS civil assessments, FBAR penalties, and potential SEC actions can all run simultaneously.
Both attorneys gained early-career prosecution experience through the Rhode Island Attorney General’s Office, and Murphy prosecuted misdemeanor criminal matters as a Town Solicitor for Rhode Island municipalities. That firsthand exposure to how the government evaluates cases, assesses cooperation value, and makes charging decisions is particularly relevant in federal tax defense — where understanding how IRS-CI referrals move through the USAO-CT, how prosecutors decide whether to add wire fraud or money laundering counts alongside tax charges, and how they evaluate pre-indictment cooperation is often the difference between a single-count disposition and a multi-count indictment.
Murphy has been selected to Super Lawyers for 14 consecutive years (Rising Star 2012–2018, Super Lawyers 2019–2025). Marin has been selected for 11 consecutive years (Rising Star 2014–2018, Super Lawyers 2019–2024) and has been named to the National Trial Lawyers Top 100. The firm has earned 451 five-star Google reviews with a 5.0 rating.
Every consultation is confidential and protected by attorney-client privilege. A federal tax case is not a tax problem — it is a criminal defense matter that requires federal criminal defense counsel. Call (860) 294-4384 for a confidential consultation.
Federal Tax Charges vs. a Tax Dispute: Why This Is Different
A tax audit is uncomfortable. A federal criminal tax investigation is categorically different. The IRS has two divisions: civil examination (audits, assessments, penalties) and Criminal Investigation (CI). If your matter has been referred to or picked up by IRS-CI, you are no longer in a tax dispute — you are the subject of a potential federal criminal prosecution.
Federal tax charges carry serious consequences. Tax evasion under 26 U.S.C. § 7201 carries up to five years in federal prison per count. Filing a false return carries up to three years. Failure to pay or file carries up to one year per count. In white-collar cases involving complex financial structures — investment funds, corporate transactions, offshore accounts — these counts stack quickly, and prosecutors routinely add Connecticut federal wire fraud (18 U.S.C. § 1343) or money laundering charges alongside the tax counts, dramatically increasing sentencing exposure.
In Connecticut, tax charges frequently appear alongside other federal fraud allegations. Recent D. Conn. prosecutions illustrate this clearly. A former senior executive at a multinational corporation in Stamford faced a nine-count indictment including wire fraud and tax evasion after allegedly diverting more than $28 million through a fraudulent shell company scheme. In a separate matter, a Greenwich investment advisor pleaded guilty in December 2025 to tax evasion stemming from the federal embezzlement of more than $5.2 million in client funds. Both cases involved IRS-CI and parallel civil proceedings.
If you are being investigated for fraud, your tax filings will be examined as part of that investigation. If you are being investigated for tax offenses, the government will look for related financial crimes. These investigations rarely stay narrow.
The Pre-Indictment Window Is Where Outcomes Are Determined In D. Conn., 100% of tax and fraud cases in FY2024 resolved by guilty plea. That means the quality of pre-indictment negotiation — not trial performance — is what determines the outcome. Retaining experienced federal defense counsel before charges are filed is the single most consequential decision you will make. Call (860) 294-4384 — 24/7 Confidential Consultations D. Conn.-admitted defense counsel available for urgent consultations.
What the Government Must Prove — and Where That Proof Can Be Challenged
Federal tax prosecution requires the government to prove willfulness — that you knew what the law required and deliberately chose not to comply. This is a meaningful element. Negligence, reliance on professional advice, complexity of the underlying transactions, and good-faith disputes about tax treatment are all relevant to willfulness analysis and can form the basis for a meaningful defense.
In investment and business contexts, tax positions are often the product of advice from accountants, tax counsel, or fund administrators. If you reported what your advisors told you, pursued positions they recommended, or relied on documentation they provided, that reliance goes directly to willfulness. Evidence of professional advice — engagement letters, emails, memoranda, tax opinions — needs to be preserved and reviewed early.
Additional defense angles depend on the specific charges:
Bank deposit analysis challenges. The government’s income reconstruction using deposit analysis often contains errors — co-mingled funds, transfers between accounts, loan proceeds, or non-income items treated as income. An independent forensic accountant can identify and document these discrepancies.
Statute of limitations. Federal tax offenses generally carry a six-year statute of limitations, though certain fraud charges can extend further. Charges based on returns or transactions outside that window may be challengeable.
Materiality. Some discrepancies are too immaterial to sustain a criminal charge even where the underlying conduct was technically incorrect.
Constructive vs. actual knowledge. In business entities with multiple owners or employees handling finances, the government must connect specific knowledge of the false filing to the individual being charged — not just to the entity.
Talk to a Federal Defense Attorney Who Understands IRS-CI Investigations in Connecticut Attorney Stefanie A. Murphy is admitted to the U.S. District Court for the District of Connecticut and holds active federal bar admissions across D. Conn., D. Mass., and D.R.I. If you’re facing a federal tax investigation or charges, a confidential consultation is the first step. Call (860) 294-4384 — Available for Urgent Consultations 24/7
Frequently Asked Questions
What’s the difference between a civil tax audit and a criminal tax investigation?
A civil audit is conducted by IRS examination and results in assessments, penalties, or adjustments. A criminal investigation is conducted by IRS Criminal Investigation (IRS-CI), a law enforcement division. If IRS-CI is involved, the potential outcome is federal prosecution, not just a tax bill. The clearest sign you’ve crossed into criminal territory: agents knocking on your door, a grand jury subpoena, or a target letter from the U.S. Attorney’s Office.
IRS agents want to interview me. Do I have to speak with them?
No. You have the right to decline any voluntary interview without providing a reason. Anything you say to IRS-CI agents can be used against you. You should not speak with federal investigators without first consulting with a federal criminal defense attorney. This applies regardless of whether you believe your explanation would help you — voluntary statements frequently do not.
My CPA handled my taxes. Can I still be charged?
Potentially, yes. The government will argue that you reviewed and signed your returns, that you knew about the income, and that reliance on your CPA does not excuse knowing participation in a false filing. However, documented professional reliance — emails, engagement letters, advice you received and followed — is directly relevant to the willfulness element the government must prove. Your CPA’s conduct and advice is part of your defense, and that evidence needs to be preserved.
What does a federal tax case typically cost to defend?
Federal criminal defense in complex financial matters generally requires significant resources. Attorney fees for federal tax defense at the pre-indictment stage typically range from $25,000 to $75,000 or more depending on complexity. Cases that proceed to trial or involve parallel SEC or civil IRS proceedings can involve substantially higher costs. The investment in experienced counsel early — before charges are filed — is almost always less than the cost of a poorly managed case that results in prosecution.
Can federal tax charges be resolved without prison time?
In some cases, yes. Factors that affect sentencing include the calculated tax loss under the U.S. Sentencing Guidelines, criminal history, cooperation with authorities, and the presence or absence of aggravating conduct such as obstruction or sophisticated concealment. Sentencing mitigation — challenging the government’s tax loss calculation, establishing acceptance of responsibility, presenting comprehensive character evidence — requires preparation that begins well before a plea is entered.
What is a federal target letter, and what should I do if I receive one?
A target letter from the U.S. Attorney’s Office means you have been identified as a target of a federal grand jury investigation. It typically states that you have the right to consult counsel, the right to refuse to testify, and that the grand jury is investigating possible violations of federal law. You should not respond to the letter without counsel. You should not contact other witnesses, destroy documents, or take any action regarding your financial records. Contact a federal criminal defense attorney immediately.
How long do federal tax investigations take?
IRS-CI investigations frequently run for two to four years before an indictment. The statute of limitations for most federal tax offenses is six years from the date the return was filed. This means the government has substantial time to build its case before you are aware that an investigation is active. By the time agents make contact, they typically have already obtained financial records, bank records, and third-party information through grand jury subpoenas.
Facing a Federal Tax Investigation in Connecticut? Call Now.
A federal tax case is not a tax problem. It is a criminal defense matter that requires federal criminal defense counsel — not your CPA, not a civil tax attorney, and not a general practitioner.
If you have received a target letter, been contacted by IRS-CI agents, learned of a grand jury investigation, or have reason to believe your tax filings are under federal scrutiny, the time to retain counsel is now — before charges are filed, before you make statements, and before the government’s theory of the case is set. See our guide to federal plea and cooperation defense in Connecticut for how proffer agreements are structured.
Marin & Murphy Law Firm handles serious federal criminal matters throughout the District of Connecticut. Attorney Stefanie A. Murphy is admitted to the U.S. District Court for the District of Connecticut (Bar No. 31712) and represents clients at all three D. Conn. courthouse locations. Consultations are confidential.
Call (860) 294-4384 to speak directly with our office about your situation. The earlier you act, the more options you have.
For a comprehensive overview of federal fraud defense in Connecticut — including wire fraud, securities fraud, healthcare fraud, bank fraud, embezzlement, and loss-amount sentencing mechanics — see our Connecticut Federal Fraud Defense page. Clients whose convictions are on appeal should see our Connecticut federal post-conviction relief page. For an overview of all federal charge types, see our Connecticut Federal Criminal Defense Attorney page.
