Caroline D. Ciraolo Representative Matters (Criminal)

  • Represented individual investigated for filing false income tax returns resulting in a loss of more than $700,000. Client charged with a single violation of 26 U.S.C. 7206(1) resulting in an advisory Guideline range of 24 to 30 months. In September, 2014, persuaded the court to grant a downward variance, resulting in sentence of probation with the condition of 12 months of home detention.
  • Represented individual investigated for filing false income tax returns.  Negotiated a misdemeanor plea to a single count of 26 U.S.C. 7207 and in May, 2014, successfully argued for a probationary sentence.
  • Represented individual investigated for embezzlement and filing false income tax returns and amended income tax returns over a twelve year period.  Negotiated a two-count plea to violation of 18 U.S.C. 1343 and 26 U.S.C. 7201.  In April, 2013, successfully challenged government’s argument against grouping, resulting in a reduced advisory Guideline range of 27 to 33 months, and persuaded to court to grant downward variance, resulting in a 15-month sentence with a recommended designation to a minimum security satellite camp.
  • Represented individual investigated for failing to file foreign bank account reports and filing false income tax returns resulting in a loss of more than $800,000.  Client charged with a single violation of 26 U.S.C. 7201 resulting in an advisory Guideline range of 24 to 30 months.  In February, 2013, persuaded to court to grant downward variance, resulting in sentence of a year and day, with a recommendation for direct placement to a local residential reentry center (formerly referred to as community confinement or halfway house).
  • Represented individual investigated for structuring and failing to file income tax returns for 10 years.  Negotiated plea to single violation of 26 U.S.C. 7201 resulting in an advisory Guideline range of 12-18 months.  In November, 2012, persuaded to court to grant downward variance, resulting in sentence of eight months in a minimum security satellite camp.
  • Represented individual investigated for structuring and failing to file income and employment tax returns for several related entities over more than five years.  Negotiated plea to single violation of 26 U.S.C. 7201.  Successfully challenged U.S. Probation Office’s position that client engaged in sophisticated means, resulting in an advisory Guideline range of 24-30 months.  In November, 2012, persuaded to court to grant downward variance, resulting in sentence of 13 months in a minimum security satellite camp.
  • Represented individual investigated for structuring and filing false individual and corporate income tax returns over more than five years.  Negotiated plea to single violation of 26 U.S.C. 7201 resulting in an advisory Guideline range of 18-24 months. In November, persuaded to court to grant downward variance, resulting in sentence of a year and a day in a minimum security satellite camp.
  • Represented individual and his related entities investigated for failure to file income tax and employment tax returns and pay related tax over a 7-year period in violation of 26 U.S.C. 7203 and failure to properly withhold under 26 U.S.C. 7206(1).  Negotiated plea to two counts of willful failure to file (misdemeanors), with an advisory Guideline range of 18 to 24 months.  In October, 2012, persuaded to court to grant downward variance, resulting in sentence of 10 months in a residential reentry center (formerly referred to as community confinement or halfway house).