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Lowther | Walker defends Georgia individuals, executives, and business owners, facing allegations of federal tax evasion, filing false returns, payroll tax violations, offshore account issues, and other complex financial crimes throughout Atlanta and Georgia. Partners Joshua Sabert Lowther and Murdoch Walker II bring over 25 years of combined experience exclusively defending high-stakes federal tax cases.
Mr. Lowther is a Wig and Gavel Award recipient known for elite courtroom advocacy. Mr. Walker utilizes his background as a former DEA Task Force Officer and state criminal investigator to dismantle aggressive government investigations. Together, they defend clients against Georgia IRS actions, protecting Atlanta business owners from financial and criminal penalties.
Lowther | Walker’s attorneys can respond within minutes, 24/7, from our downtown Atlanta offices:
Contact Our Atlanta Offices:
No-obligation. Fully confidential.
Call Us Today: (404) 496-4052
Our attorneys combine sophisticated courtroom advocacy with a deep understanding of the federal tax laws and financial regulations that underpin complex tax fraud prosecutions.
Representing clients facing federal tax investigations throughout Atlanta and Georgia, Lowther | Walker’s attorneys know how the IRS Criminal Investigation Division and federal prosecutors build these cases. The firm’s attorneys will expose weaknesses in the government’s evidence by challenging allegations of willfulness and intent while dissecting financial records, forensic accounting, and tax reporting documentation. It’s how they’ve set the standards for tax fraud defense services over 30 years, serving clients across Georgia and nationwide.
Few federal tax firms can match Lowther | Walker for experience in high-stakes Atlanta white-collar litigation, where they protect clients at every stage, whether during an investigation, in federal court, or through negotiated resolutions.
Investigation terminated; no prosecution. DOJ notified our client that she was the target of a multi-million-dollar public corruption, money-laundering, and tax-fraud investigation that FBI and IRS-CI were conducting. The client’s former atto rney had arranged […]
Investigation terminated; no prosecution. DOJ notified our client that she was the target of a multi-million-dollar public corruption, money-laundering, and tax-fraud investigation that FBI and IRS-CI were conducting. The client’s former atto rney had arranged […]
Most tax fraud cases in Metro Atlanta do not begin with a raid. They begin quietly inside a standard IRS civil audit. When an auditor uncovers what they believe are badges of fraud, such as dual accounting records, unrecorded cash receipts, or altered documents, they are required to freeze the civil examination without notifying you and refer the file to IRS Criminal Investigation.
If your civil audit suddenly stalls, if the auditor stops asking for routine receipts, or if two armed IRS Special Agents arrive unannounced at your home or business in Buckhead, Alpharetta, or Midtown, your case has officially converted into a federal criminal prosecution.
Lowther | Walker intervenes at this exact moment in a tax fraud investigation. Located in downtown Atlanta at Centennial Tower, the firm’s federal defense attorneys step between you and federal agents to halt questioning, preserve your constitutional rights, and work to keep civil tax disputes from turning into criminal indictments.
Federal tax prosecutions in the Northern District of Georgia are built on specific statutes. Prosecutors rarely file a single charge. They select statutes that maximize their leverage during plea negotiations.
| Statute | Charge | What Prosecutors Must Prove | Max Federal Prison Sentence |
| 26 U.S.C. Section 7201 | Tax Evasion | An attempt to evade or defeat a tax, an underlying tax deficiency, and an affirmative willful act. | Up to 5 years per count |
| 26 U.S.C. Section 7206(1) | Filing a False Return | Signing a tax document under penalty of perjury knowing that a material item is false or incorrect. | Up to 3 years per count |
| 26 U.S.C. Section 7202 | Employment Tax Fraud | Willfully failing to collect, account for, or pay over employee payroll and withholding taxes. | Up to 5 years per count |
| 31 U.S.C. Section 5322 | FBAR Violations | Willfully failing to report offshore bank accounts holding over 10,000 dollars. | Up to 5 or 10 years |
IRS Criminal Investigation Special Agents operating out of the Atlanta Field Office target specific commercial sectors across Georgia. Our firm frequently defends clients facing investigations tied to:
The Georgia film tax credit program has drawn intense federal scrutiny. Federal prosecutors aggressively investigate production companies, studio owners, and investors for allegedly inflating qualified in-state expenditures or brokering fraudulent tax credits.
Business owners who use employee tax withholdings to cover operational cash flow during difficult financial quarters face criminal prosecution under 26 U.S.C. Section 7202. The government views this not as a debt, but as direct theft of federal funds.
The U.S. Attorney’s Office for the Northern District of Georgia continues to cross-reference pandemic relief applications against official IRS tax filings. Discrepancies in reported revenue or payroll numbers between loan applications and tax returns routinely trigger federal fraud indictments.
Under federal tax law, negligence, poor recordkeeping, bad accounting advice, or confusion about complex tax codes is not a crime. To secure a conviction, federal prosecutors must prove willfulness beyond a reasonable doubt, meaning you voluntarily and intentionally violated a known legal duty.
Lowther | Walker’s tax fraud attorneys proactively dismantle the government’s proof of intent:
If you provided complete, accurate financial records to a CPA, tax preparer, or tax attorney and relied on their advice, you lack the specific intent required for criminal fraud.
The Federal Sentencing Guidelines for tax crimes are dictated almost entirely by the calculated tax loss. IRS agents routinely overestimate this figure by ignoring legitimate, allowable business deductions. We work with forensic tax accountants to audit the government calculations and dramatically lower the potential sentencing range.
If you know you have unfiled tax returns or unreported offshore income, but IRS Criminal Investigation has not yet initiated an investigation, entering the official IRS Voluntary Disclosure Program can protect you from criminal prosecution entirely.
| Step | Required Action | Strategic Purpose |
| 1. Polite Refusal | Explicitly state you will not answer questions without your attorney present. | Prevents federal agents from gathering damaging admissions or inconsistent statements. |
| 2. Request Identification | Obtain the full names, badge numbers, and field office location of the agents. | Identifies which specific task force or division is driving the investigation. |
| 3. Withhold Documents | Do not hand over flash drives, physical files, or account passwords without a warrant. | Protects your Fourth Amendment rights against unlawful search and seizure. |
| 4. Contact Defense Counsel | Call Lowther | Walker immediately at their Atlanta Centennial Tower Offices | Allows experienced federal attorneys to take over all communications with federal agents. |
When your freedom and financial legacy are on the line, you need a law firm completely dedicated to federal criminal defense. State-level criminal attorneys rarely possess the granular knowledge of the federal tax code required to fight an IRS criminal investigation.
Here is why Atlanta executives and business owners trust Lowther | Walker:
Our partners have dedicated their careers to federal criminal defense, representing clients from pre-indictment investigations through complex federal trials and appeals.
We understand the opposition because we know how they build cases. By utilizing deep investigative backgrounds and consulting with former federal agents, we conduct confidential internal investigations and counter the government narrative before charges are filed.
Our primary goal is always deterrence. By launching aggressive pre-indictment investigations, we frequently persuade government prosecutors to terminate criminal proceedings and decline prosecution.
Located in Centennial Tower, our team is positioned right at the heart of the Atlanta federal legal district and is available to respond to urgent legal emergencies.
Lowther | Walker’s attorneys are available to respond 24/7 to IRS agents on your behalf. Book a free consultation now for clear answers to your tax fraud defense questions based on decades of experience in federal tax matters.
No-obligation. Fully confidential.
Call Us Today: (404) 496-4052
Do not call the agent back yourself. Contact a local criminal tax defense lawyer immediately. In Georgia, state tax crimes are investigated by the Georgia Department of Revenue (DOR) Office of Special Investigations (OSI), whose agents are sworn, armed law enforcement officers. Your attorney will contact the investigator on your behalf to determine if you are a witness, subject, or target, preventing you from accidentally making incriminating statements.
Under Georgia Code § 48-1-7, tax evasion is a crime that can be prosecuted as a misdemeanor or elevated to a felony depending on the circumstances. You can only be sentenced to jail or prison if the state proves you actively concealed assets, falsified information on your return, or deliberately used a scheme to evade the assessment or payment of the tax.
While Georgia law does recognize a limited accountant-client privilege for civil matters, it generally does not protect you in criminal tax investigations, and there is no accountant privilege in federal proceedings. Anything you say to your CPA or bookkeeper can potentially be subpoenaed by a grand jury, forcing them to testify against you. You must communicate exclusively through a criminal defense attorney to protect your conversations under attorney-client privilege.
A tax audit is conducted by a DOR or IRS auditor seeking to correct errors and collect owed money plus civil penalties (such as a 5% penalty for negligent underpayment). A criminal tax investigation is conducted by DOR OSI agents or IRS Special Agents who are actively building a case to indict you for a tax crime. If a standard DOR auditor uncovers “badges of fraud” during a routine audit, they can secretly refer your case to the OSI for a criminal investigation.
The Georgia Department of Revenue offers a Voluntary Disclosure Agreement (VDA) program that encourages taxpayers with unfiled returns or underreported liabilities to come forward proactively. If you apply and are accepted, the DOR generally waives all penalties and limits the “look-back” period for assessing taxes (usually to just the past three years). However, you are only eligible if you apply before the DOR contacts you about an audit or compliance issue.
Good faith reliance on professional advice is a potent defense against bank fraud. The government must prove you acted with “knowing” intent to defraud. If you provided inaccurate information because you were following the incorrect advice of an accountant or attorney, you lacked the requisite specific intent to commit a crime
Our attorneys intervene during the pre-indictment phase. Based in Centennial Tower in downtown Atlanta, we communicate directly with federal prosecutors, enforce your Fourth Amendment rights against unlawful searches, and aggressively litigate pre-trial motions to suppress illegally obtained evidence, often crippling the government’s case before it reaches trial.
