Criminal tax preparation · A practical guide
Tax Evasion Under 26 U.S.C. § 7201: Preparing the Personal Record
A statutory label does not explain an individual’s full history. Work with defense counsel on the legal case and with SAG on a documented, accurate preparation record.
By Joseph De Gregorio · Federal Sentencing Reduction and Early Release Strategist
Founder and President, Sentencing Advocacy Group
Published November 5, 2026
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Read the charge as written
Section 7201 addresses attempts to evade or defeat tax or its payment. The official statute is the starting source, but counsel must explain the allegation, applicable law and potential consequences. This guide does not provide a test for whether particular conduct satisfies the offense.
Identify the exact charging document, count, tax periods and persons or entities named. Keep allegations distinct from admitted facts, disputed matters and background information. Do not rewrite the charge into a broader or narrower account without counsel’s review.
Map the tax-period history
For each relevant period, list the return, original filing information, later amendments, examination notices and payment records. Identify the preparer and available supporting documentation. Preserve different versions so a reviewer can understand the sequence.
Where the case involves both a business and personal tax affairs, maintain separate schedules. Record actual responsibilities and access to information rather than assuming that ownership describes every transaction or decision.
Keep calculations and personal history separate
The sentencing tax-loss question requires legal and financial analysis. SAG’s record organization can identify the source documents and unresolved factual questions, while counsel and appropriate experts evaluate the calculation. Do not treat civil balances or a general fraud calculator as a substitute.
Personal preparation addresses different questions: who the person is, what responsibilities they actually held, how they understand the relevant conduct and what documented changes have occurred. Keep each statement connected to a date, source or reliable supporting record.
Document completed corrective action
A compliance change should identify what was done, when, by whom and how it is being maintained. A proposal to change accountants is different from an executed engagement and a completed review. A promised payment differs from a confirmed payment.
Do not characterize a corrective step as resolving criminal exposure. Counsel should advise on amended filings, disclosures and communications with agencies. SAG can maintain the factual chronology and organize proof of completed actions within the agreed scope.
Prepare for the presentence process if it becomes relevant
A presentence preparation assignment can include employment history, family responsibilities, education, treatment records handled through appropriate channels, character-support guidance and practical plans. Accuracy matters more than volume.
Joseph works directly with the client and coordinates review points with counsel. The deliverable should identify factual gaps and distinguish documents from recollection. Legal arguments, objections and court submissions remain counsel’s responsibility.
Sources and related preparation
Official United States Code: 26 U.S.C. § 7201. Source checked November 5, 2026. Counsel must evaluate the rules and facts applicable to your case.
Can this guide determine whether my conduct is tax evasion?
No. That requires legal advice based on the facts and applicable law. This page describes preparation support, not an assessment of criminal liability.
A defined engagement with Joseph De Gregorio
Retain qualified federal defense counsel first for an investigation or criminal charge. Agree on the scope, records, authorized recipients and review dates before SAG’s work begins. Counsel retains legal advice, strategy and submissions. SAG can deliver an indexed personal record, a chronology, a factual gap list and an agreed preparation schedule. An engagement does not automatically make every communication privileged; counsel determines the appropriate arrangements.
SAG serves clients nationwide from Freehold, New Jersey, with travel arranged for cases. Tell Joseph your current stage and next deadline. Do not send case documents or sensitive allegations through the initial website form.
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SAG is not a law firm and does not provide legal or tax advice. Courts and agencies determine outcomes. No sentence, charging decision or release date is guaranteed.