Obstructing Tax Administration lawyer Maryland, MD

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Obstructing Tax Administration lawyer Maryland, MD



Obstructing Tax Administration lawyer Maryland, MD

You open a letter from the Internal Revenue Service’s Criminal Investigation Division. It states you are under investigation for willfully obstructing or impeding the administration of the internal revenue laws. Suddenly, your business, your livelihood, and your freedom are on the line. Federal agents have been examining your financial records, interviewing witnesses, and building a case. The U.S. Attorney’s Office for the District of Maryland may soon seek an indictment under 26 U.S.C. §§ 7201–7207. At Law Offices Of SRIS, P.C., Mr. Sris and the firm’s Of Counsel attorneys understand the federal criminal process and the serious consequences these charges carry. Reach our location at (888) 437-7747 to schedule a consultation. Law Offices Of SRIS, P.C. – Advocacy Without Borders.

What Obstructing Tax Administration Means in Maryland

Federal tax obstruction covers a broad range of conduct: tax evasion, willful failure to file or pay, concealing assets, destroying records, or otherwise impeding the lawful assessment and collection of taxes. Prosecutions are brought by the U.S. Attorney’s Office in the District of Maryland, with cases heard in the U.S. District Court in either the Baltimore or Greenbelt divisions. The IRS Criminal Investigation unit leads the investigation, often working alongside other federal agencies. Because these matters are federal, they proceed under the Federal Sentencing Guidelines, and parole has been abolished in the federal system.

The potential penalties are severe. Under the applicable statutes, a conviction can result in imprisonment, supervised release, fines, and restitution. A key numeric that frames the risk:

Under 26 U.S.C. § 7201-7207, a conviction for obstructing tax administration carries a maximum penalty of up to five years imprisonment per count.

Source: 26 U.S.C. § 7201.

Reviewed by Mr. Sris, admitted in VA/MD/DC/NJ/NY.

A person charged with multiple counts faces the possibility of consecutive sentences. Even an investigation alone can freeze assets, damage a professional reputation, and lead to the loss of a business or professional license. Early engagement with an attorney experienced in federal tax cases is critical—before charges are filed, an attorney may be able to present evidence to the U.S. Attorney’s Office that avoids prosecution or narrows the case.

Defending Against Federal Tax Obstruction Charges

Every defense strategy is tailored to the specific facts. Common approaches include challenging whether the government can prove an intentional, willful violation—a required element in tax obstruction cases. A conviction for a tax offense requires proof beyond a reasonable doubt that the accused acted with the purpose of violating a known legal duty. If the government’s case relies on circumstantial evidence of willfulness, your attorney may attack the inferences drawn from that evidence. A thorough defense also examines whether the IRS followed proper administrative procedures, whether the tax computation is accurate, and whether any statute of limitations has expired.

In some cases, negotiations with the U.S. Attorney’s Office can lead to a pretrial diversion agreement, a deferred prosecution, or a plea to a lesser charge. Mr. Sris and the firm’s Of Counsel attorneys have experience appearing in U.S. District Court for the District of Maryland, and they understand how federal prosecutors and investigative agencies build these cases. That insight helps in identifying weaknesses in the government’s evidence and in presenting mitigating factors to the court.

What to Expect During a Federal Tax Obstruction Investigation

Federal tax investigations do not begin in the open. The IRS Criminal Investigation Division typically works quietly for months or years before a subject even becomes aware. You may learn of an investigation through a target letter, a grand jury subpoena served on your bank or accountant, or a search warrant executed at your home or business. At that point, you need counsel immediately. Anything you say to investigators can be used against you. Allowing a lawyer to handle all communications with the government protects your rights and preserves your defense options.

After an investigation, the case may be presented to a federal grand jury. If an indictment is returned, you will be arraigned in U.S. District Court for the District of Maryland. The case then proceeds through pretrial motions, discovery, and possibly a trial. Throughout this process, your attorney will challenge the admissibility of evidence, negotiate for a favorable resolution, and prepare a compelling defense for trial if necessary. The timeline varies considerably—depending on the complexity of the alleged scheme, the volume of financial records, and the court’s calendar.

About Mr. Sris and the Firm’s Of Counsel Attorneys

Mr. Sris, Owner and Founder of Law Offices Of SRIS, P.C., is a former prosecutor who has practiced law since 1997. He is admitted in Virginia, Maryland, the District of Columbia, New Jersey, and New York. Mr. Sris testified before the Virginia House Courts of Justice Committee in support of 2019 HB 635 (chief patron Del. David Bulova). His experience encompasses federal criminal defense, including tax obstruction and related financial crimes.

The firm’s Of Counsel attorneys bring extensive combined legal experience. Mr. Sris and the firm’s Of Counsel attorneys appear in U.S. District Court for the District of Maryland, handling everything from pre-indictment negotiations through sentencing. The firm’s Rockville, Maryland location serves clients throughout Montgomery County, Prince George’s County, Howard County, Anne Arundel County, Frederick County, and all other Maryland counties. To request a consultation, call (888) 437-7747.

Frequently Asked Questions

What is obstructing tax administration under federal law?

Obstructing tax administration refers to willful conduct that impedes or interferes with the IRS’s ability to determine, assess, or collect federal taxes. This can include tax evasion, filing false returns, destroying records, concealing income or assets, or corruptly endeavoring to obstruct the lawful functions of the IRS. The government must prove beyond a reasonable doubt that the defendant acted with an intent to violate a known legal duty. Because the statutes are broad, a wide variety of conduct can be charged, from failing to file a return to complex schemes involving offshore accounts.

How does the IRS investigate tax obstruction in Maryland?

The IRS Criminal Investigation Division (IRS-CI) conducts the investigation, often in coordination with other federal agencies such as the FBI or the U.S. Attorney’s Office for the District of Maryland. Special agents gather financial records, interview witnesses, and may execute search warrants. If you receive a target letter or grand jury subpoena, the investigation has likely been underway for some time. In Maryland, cases are typically prosecuted in either the Baltimore or Greenbelt division of the U.S. District Court. Early legal representation can be critical to understanding the scope of the investigation and protecting your rights.

Do I need a lawyer if I am under investigation for tax obstruction?

Yes, you should retain an attorney experienced in federal criminal tax defense as soon as you learn of any investigation. Even before charges are filed, your lawyer can communicate with the U.S. Attorney’s Office, seek to limit the scope of the investigation, and present evidence that may avert prosecution. Statements made to investigators without counsel can be used against you. An attorney can also advise you on preserving attorney-client privilege and avoiding additional charges such as obstruction of justice.

What are the potential penalties for obstructing tax administration?

A conviction under 26 U.S.C. §§ 7201–7207 can result in imprisonment of up to five years per count, a term of supervised release, significant fines, and an order of restitution. The Federal Sentencing Guidelines will determine the advisory sentencing range based on the amount of tax loss, the sophistication of the scheme, and other factors. Because there is no parole in the federal system, a person sentenced to prison will serve a substantial portion of the sentence. A conviction can also result in professional license revocation and lasting damage to one’s reputation and career.

Can tax obstruction charges be resolved without trial?

Many federal tax obstruction cases are resolved through pretrial negotiations, including deferred prosecution agreements or plea agreements to lesser charges. Whether a resolution is achievable depends on the strength of the government’s evidence, the amount of tax loss, the defendant’s prior record, and the willingness of the U.S. Attorney’s Office to negotiate. An attorney who understands federal criminal tax procedure can assess the viability of a pretrial outcome and, if it is not in the client’s interest, prepare a defense for trial.

How do I find a federal tax obstruction lawyer in Maryland?

Look for an attorney who practices federal criminal defense, is admitted in the District of Maryland, and has experience with tax-specific federal charges. Law Offices Of SRIS, P.C. has represented clients in federal criminal matters since 1997. Mr. Sris and the firm’s Of Counsel attorneys are admitted in Maryland and appear regularly in the U.S. District Court for the District of Maryland. To schedule a consultation with Mr. Sris, call (888) 437-7747.

Outbound authority sources: 26 U.S.C. § 7201 | U.S. District Court for the District of Maryland

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Reviewed by Mr. Sris, Owner and Founder.

Attorney advertising. This page is for general informational purposes only and does not constitute legal advice, nor does it create an attorney-client relationship. Statutes and their application change and vary by case. Prior results do not guarantee a similar outcome; results may vary. For advice about your specific situation, consult a licensed attorney. Attorney responsible for this advertising: Mr. Sris.