Criminal Tax and Customs Enforcement

Dave Stetler served with the Criminal Tax Division of the Office of Chief Counsel for the IRS. SR draws on their experience as it represents clients in nationally significant criminal tax prosecutions.


When the IRS decided to attack sophisticated income tax shelters, it produced the largest criminal tax fraud prosecution in American history. SR trial lawyers played a leading role at the four-month trial in Manhattan, defending an attorney accused of developing highly complex shelters promoted by major law firms, banks, and financial consultants. The case, United States v. Daugerdas, et al., drew national media coverage for the cutting-edge tax principles at stake, as well as its remarkable post-trial disclosure of juror misconduct.

When an auto enthusiast imported a McLaren F-1 racing car into the United States, he found that the danger he faced was not in the 250 mph top speed of that vehicle, but in the criminal indictment brought by the Bureau of Customs Enforcement. SR lawyers took the case to a jury trial and demonstrated that the fault was not in the importation, but in the confusing and contradictory forms issued by various agencies of government. Our client was acquitted on all charges. United States v. Wierenga.

SR lawyers represented a businessman from northern Indiana who was indicted on charges that he committed tax fraud and sought to defraud the IRS through his payment of millions of dollars to a captive off-shore insurance company. After a three-week jury trial in federal district court, our client was acquitted on all charges. United States v. Stamatakis.

SR played a key role in the “Honeygate” investigation, a nationwide inquiry into the transshipment of Chinese honey through other countries and the mislabeling of Chinese honey as other products. The government alleged a conspiracy to avoid anti-dumping duties imposed by the Department of Commerce. SR defended multiple clients in connection with the federal criminal investigation, related forfeiture proceedings, and in the subsequent civil class action litigation.

SR has a strong track record of success in negotiating extremely favorable outcomes in criminal tax matters. By taking affirmative and prompt action, SR lawyers have been able to obtain plea agreements that greatly minimize, or even eliminate, jail sentences resulting from criminal tax violations.

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