Posted by: Taxlitigator | June 16, 2026

District Court Shoots Down Use of Wire Fraud Statute to Charge Tax Crimes by Robert S. Horwitz

Joseph Garza is a Dallas attorney who allegedly helped clients evade taxes on more than $1 billion of income through a circular flow of funds between the clients and shell service corporations that purported to provide services to the clients’ businesses and shell investment corporations. He was initially charged by the United States with eighteen counts of wire fraud, in violation of 18 U.S.C. §1343, one count of conspiracy to commit wire fraud, in violation of 18 U.S.C. §1349, twenty-four counts of aiding and abetting the filing of false and fraudulent tax returns, in violation of 26 U.S.C. §7602(2), and one count of conspiracy to defraud the United States in violation of 18 U.S.C. §371. A superseding indictment added three CPA as co-defendants. United States v. Joseph Garza, Criminal No. 3:22-CR-0390-S (N.D. Tex).

Robert Horwitz a Principal of Hochman Salkin Toscher Perez P.C. has over 40 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year. He was previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section. He is the 2022 recipient of the California Lawyers Association Joanne M. Garvey Award for lifetime achievement and outstanding contributions to the field of tax law.

For more information, please contact Robert S. Horwitz at horwitz@taxlitigator.com


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