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While the IRS has a 90 percent conviction rate in criminal tax cases, recent defense victories show that a criminal tax case can be won, negotiated down to a favorable plea, and/or resolved with a lenient sentence. A defense attorney can combat the willfulness theory by arguing that the defendant acted in good faith. Furthermore, reliance on a tax professional is a complete defense in certain circumstances. Creative and thorough defense lawyering can go a long way in the criminal tax arena.
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