Criminal tax cases against San Diego taxpayers are charged downtown — federal ones by the U.S. Attorney for the Southern District of California, state ones by county prosecutors on referrals from the CDTFA, EDD, and FTB. If an agency’s criminal side has touched your case, the civil playbook no longer applies.
The touch usually looks like one of three things: IRS Criminal Investigation special agents appearing — often unannounced, in pairs, at your home or business; a civil audit that suddenly goes quiet or narrow (the eggshell-to-referral pattern); or a state agency’s investigations unit sending correspondence that reads different from collection mail. Each has its own immediate rule, and all three share one: statements made in the first conversation do more damage than anything found in the records.
The San Diego criminal-tax landscape
Our practice covers all four agencies’ criminal arms — the full criminal tax practice, with dedicated pages on CDTFA investigations (POS-suppression and cash-business cases, a real pattern in San Diego’s restaurant economy), EDD criminal referrals (willful misclassification and unreported payroll), FTB investigations, and federal cases — § 7201 evasion, § 7206 false returns, § 7203 failures to file. Where exposure exists but no investigation has started, voluntary disclosure remains the tool that most reliably converts criminal risk into a civil bill — and its availability ends the moment the government finds you first.
If agents have already made contact
Take their cards, confirm counsel will respond, and stop there — politely, without answering “just a few questions.” Coordinate any agency contact through counsel from that day forward, and preserve everything. Criminal tax investigations are methodical; the defense should be too. We handle these matters from San Diego, privileged from the first call.
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Related: criminal tax defense practice · what tax evasion actually carries · all San Diego practice areas.
By Sam Brotman, JD, LLM, MBA — managing attorney, Brotman Law. CA Bar No. 274966. Last updated August 29, 2026.
