Michigan Tax Lawyer Allegedly Hid Millions in Switzerland

Michigan Tax Lawyer Allegedly Hid Millions in Switzerland

A Michigan Tax Lawyer Allegedly Evaded $3M in Tax

The purpose of a Tax Lawyer is to help Taxpayers with their tax problems. While Lawyers are supposed to protect their clients, sometimes a lawyer may be tempted to stray – which is allegedly what happened here in the case of US v Freeman. Mr. Jeffrey Freeman is a Tax Lawyer based in Michigan. He was representing a client who had a significant tax liability and penalties due and owning. The IRS had deemed the penalties and interest uncollectible – but the client was not made aware. Instead, the Attorney told the client that he paid the penalties with the Client’s money (the money was maintained in an Attorney Holding account)  — but instead, he allegedly moved the money overseas to Switzerland and did not pay tax on the ill-gotten gains.

Let’s take a look at the Compliant:

      • Jeffrey Freeman was a resident of Oakland County, Michigan, and was an attorney licensed to practice in the State of Michigan. Freeman’s legal specialty was civil and criminal tax matters, and he maintained an office in Birmingham, Oakland County, Michigan.
      • In 2012, Freeman was retained by client A.V. to assist her with a criminal tax probe.
      • A.V., a Canadian citizen who resided for a time in Las Vegas, Nevada, owned a business that sold cosmetic products. A.V. incurred substantial tax liabilities in tax years 2000-2002, which attracted the attention of the Internal Revenue Service (IRS) and eventually led to an investigation by the IRS.
      • Upon being informed of the tax probe, A.V. sought to retain counsel. A.V. eventually identified and retained Freeman to represent her interests and resolve her tax investigation with the IRS.
      • In or about November 2012, A.V. wired approximately $15 million to an attorney trust account Freeman opened at Citizens’ Bank in Bloomfield Hills, Michigan. Freeman was to use these funds to resolve A.V.’s tax liability.
      • In or about November, 2012, Freeman paid over to the IRS approximately $8,409,301, which represented the tax due and owing for A.V. for tax years 2000- 2002. This payment did not resolve penalties and interest on that amount.
      • In or about February, 2013, the IRS deemed the penalties and interest on A.V’s tax debt (penalties and interest that totaled approximately $3.4 million) “uncollectable.” Eventually, the IRS wrote off penalties and interest altogether on A.V.’s tax debt.
      • No later than May 2013, Freeman became aware that the IRS had deemed the penalties and interest on A.V.’s tax debt uncollectable.
      • In or about May 2013, Freeman wired $2 million of the funds A.V. had provided him from his trust account at Citizen’s Bank to a bank account in the name of”Rozet Assets” at HypoSwiss Privatebank AG (CH) in Switzerland. In or about October 2013, Freeman wired an additional $4.5 million of the funds provided by A.V. from his trust account to the same Swiss bank account.
      • In or about August 2013, Freeman advised A.V. that he had resolved the outstanding penalties and interest on A.V.’s account with the IRS for approximately $6.5 million.
      • Freeman had not in fact resolved A.V.’s outstanding penalties and interest for approximately $6.5 million, nor did he ever transfer those funds to the IRS.
      • After several extensions, Freeman filed a 1040 U.S. joint tax return for tax year 2013 on or about May 7, 2015. Freeman did not report any ofthe $6.5 million he embezzled from A.V. on that tax return. As a result of this underreporting of taxable income, Freeman evaded paying approximately $2,781,882 in additional tax due and owing.

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