In This Issue


The goal of this e-newsletter is to provide you critical, inside information that will help you prevail when defending an IRS criminal case. We will do this by sharing the knowledge we have from our 25+ years of experience as an IRS Special Agent. 


We are grateful to have the opportunity to provide you this valuable information via our monthly e-newsletter and our unparalleled forensic accounting and investigative services.


We take special care to ensure the information we provide you in "The Beacon" is the latest and most current information available. In this edition, we have addressed the impact of the structuring law on small business owners.




We want to write about topics that will assist you in prevailing with criminal IRS cases. Please e-mail us your topics of interest to 


We encourage you to share our e-newsletter with others in your sphere of influence.




Edmond J. Martin

Principal, Chief Investigator
Certified Fraud Examiner (CFE)

Texas Certified Investigator (TCI)


Impact of the Structuring Law on Small Business Owners      

The stated mission of Criminal Investigation (CI) is to "serve the American public by investigating potential criminal violations of the Internal Revenue Code and related financial crimes in a manner that fosters confidence in the tax system and compliance with the law." (Internal Revenue Manual (IRM) Section (09-10-2008). On the near-term horizon, Structuring Investigations of criminally derived income (illegal income) will take the forefront according the Chief of Criminal Investigation (CI), Richard Weber.


As a result of the potential misuse of the Structuring Law under Title 31 USC 5317(a) in legal income cases, the CI Chief Weber advised The New York Times on October 25, 2014 the following:


"After a thorough review of our structuring cases over the last year and in order to provide consistency throughout the country (between our field offices and the U.S. attorney offices) regarding our policies, I.R.S.-C.I. will no longer pursue the seizure and forfeiture of funds associated solely with "legal source" structuring cases unless there are exceptional circumstances justifying the seizure and forfeiture and the case has been approved at the Director of Field Operations (D.F.O.) level. While the act of structuring - whether the funds are from a legal or illegal source - is against the law, I.R.S.-C.I. Special Agents will use this act as an indicator that further illegal activity may be occurring. This policy update will ensure that C.I. continues to focus our limited investigative resources on identifying and investigating violations within our jurisdiction that closely align with C.I.'s mission and key priorities. The policy involving seizure and forfeiture in "illegal source" structuring cases will remain the same."


Article- Law Lets I.R.S. Seize Accounts on Suspicion, No Crime Required. October 25, 2014.


According to the above letter from the Chief CI, it appears that seizures under Title 31 USC 5317(a) will have less impact than in the past on the average non-criminal citizen with legal income deposited in a structured manner. Special Agents will have to do more than look at Financial Crimes Enforcement Network (FinCEN) reports to determine if structuring of deposits is taking place. They will have to do an actual investigation that includes... Read More  

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At Sage Investigations we are dedicated to serving our clients nationally, to help them navigate the difficulties of dealing with the IRS, and other complex (forensic) financial fraud investigations both civil and criminal. By narrowing our focus to our primary strength of following the money, we steer our knowledge, efforts, and experience to financial issues. We help our clients propel their cases forward by assisting in the review, acquisition, and organization of financial records, evaluating the elements of their cases, and helping create winning strategies. Through the use of our proprietary advanced financial investigative technology we analyze complex financial data quickly, easily and efficiently, saving our client's time and money.


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