For an initial consultation, we require the client to fill out a short questionnaire and prepare a brief chronology. We can then review the facts prior to the conference, saving Q&A time during the consultation, and "hit the ground running," thus allowing time with the client to explore in more detail the facts and client's options. We can read faster than anyone can talk (even if you are from New York City). It takes less time to read a client's factual paperwork than to listen verbally to all of the facts. The fee for the initial consultation: $500 to $1,000.
Many cases require a full evaluation which would include gathering information, reviewing documents, calculating and crunching numbers, applying facts to various options available, and coming up with potential short-term as well as long-term solutions. An evaluation concerning civil taxes and/or bankruptcy issues is generally a minimum $5,000 retainer. For criminal cases the retainer is higher, depending on the type of case and issues, usually at least $10,000.
- Civil tax/collection. Whether your civil tax problem concerns an IRS or State tax notice of monies due, non-filing of returns, lien, levy, seizure of property, Tax Court case, Court of Appeals, administrative appeal, or audit, we can assist you in considering your viable options and developing the best strategy. Some options may include, among others: installment agreement, offer in compromise, statute of limitations, uncollectible, bankruptcy, pay or borrow and pay, or a combination of these.
- Bankruptcy planning. We have assisted clients in discharging through bankruptcy millions of dollars in income and other tax debts. But the rules are complicated and a miscalculation of even one day could be devastating. Tax/bankruptcy planning requires detailed analyses of all facts, numbers crunching, and evaluating the potential results, as well as careful strategic planning.
- Criminal tax. In a criminal case one cannot "settle up" with IRS merely by paying the tax, penalty and interest that might be owed. Once you are aware that you are under investigation, we can assist in trying to convince the government to drop the case. There are several levels at which this is possible. The investigation can take as long as six years, from start to indictment, and usually cases take two to four years. If the case proceeds forward, we will advise you of your options concerning negotiating a plea agreement or going to trial, as well as issues concerning the Federal Sentencing Guidelines, which dictates what kind of jail sentence and/or fines you could face.
- Criminal Case Responsibility Options. It is important that you hire someone to represent you NOW if you have not yet done so. Our responsibility in the case can vary: we can do everything from taking on full responsibility for the case, to acting as a consultant to you proceeding pro se, or acting as a consultant to your local counsel. Retainer and fees vary depending on responsibility.
- Litigation. Mac MacPherson has years of litigation experience ranging from civil RICO suits to defense of federal tax evasion charges. Mac has tried over 55 criminal tax cases in 24 states. The sooner you have on board an experienced litigator, who is certified in both tax and in criminal law, the better prepared you become. In the military tradition, MacPherson, a West Point graduate, the "Courtroom Commando," calls it "full metal jacket."
- Civil, criminal, and bankruptcy. There are major differences between criminal and civil tax matters and bankruptcy, but there are connections between the three, and each area must be evaluated with consideration of the others. We take an holistic view to problem solving: the "West Point Systems Engineering" approach.
- Offshore/Tax Shelters. If you have "invested" money offshore, or are involved in a tax shelter (what IRS calls an "abusive tax shelter"), you need to know how IRS proceeds in such cases and you what options may be available to you. We represent clients in both areas.
Our Expectations Of Our Clients.
Our obligation to our clients includes giving written opinions of options and expected results. We advise client of the law, keep client informed as necessary, and manage the case. In order to meet our obligations and serve the client efficiently, we require our clients to meet their obligations, which include:
- To complete fully and accurately any questionnaire and/or other charts;i.e., do their "homework;"
- Supply accurate, updated, timely information, in writing;
- Respond promptly to attorney requests for additional information;
- Understand what is to be accomplished; if not understood, ask the attorney or legal assistant;
- Attend court as and when necessary;
- Keep attorney advised, in writing, of changed circumstances; e.g., address/phone; loss or change of job or financial condition.
Your questions may include: What happens in the civil tax case even if I win the criminal case? If I lose the criminal case on failure to file, can I file bankruptcy, and which type? What about restitution? If my case is civil now, do I have to worry about a criminal investigation? How will I pay the liability? Will I lose my home?
How We Can Help.
We can conduct a detailed evaluation of your case; explain your viable options; work with and advise your CPA, attorney, accountant, or tax preparer; handle the civil and criminal tax litigation; try to solve your tax collection problem; act as a consultant to your bankruptcy attorney; try to prevent a criminal investigation and prosecution; and defend you in a criminal tax case. We can handle "cradle to grave:" audit to appeal to the U.S. Supreme Court.
The MacPherson Group
Tax Defense Attorneys
"Major Mac" - the "Tax Terminator"/"Courtroom Commando"