# Justice Manual § 6-4.122: United States Attorney's Grand Jury Investigations and Prosecutions

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/JM_S6-4.122

## Section

- **Citation:** Justice Manual § 6-4.122
- **Heading:** United States Attorney's Grand Jury Investigations and Prosecutions
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** DOJ Justice Manual / Title 6: Tax / 6-4.000 - Criminal Tax Case Procedures / Justice Manual § 6-4.122

## Text

Tax Division Referrals for Prosecution.
The Tax Division authorizes the United States Attorneys’ Offices to conduct grand jury investigations into matters arising under the internal revenue laws to the extent necessary to perfect those tax charges that the Tax Division refers for possible prosecution.
Tax Division Referrals for Grand Jury Investigation.
The Tax Division authorizes the United States Attorneys’ Offices to conduct grand jury investigations into matters arising under the internal revenue laws to the extent necessary to 1) perfect the tax charges for which the Tax Division authorizes an investigation or 2) determine whether the Tax Division should authorize prosecution.
See
JM 6-4.242
.
Expansion of Non-tax Grand Jury Investigation to Possible Federal Criminal Tax Violations.
The Assistant Attorney General, Tax Division, has delegated limited authority to the United States Attorneys’ Offices to expand non-tax investigations in order to inquire into possible federal criminal tax violations, designate targets (subjects), determine the scope of the expanded investigation, and terminate such proceedings. Before a United States Attorney’s Office may file an information or seek the return of an indictment on matters arising under the internal revenue laws in an expanded investigation, however, the Tax Division must first authorize the specific tax charges.
See
Tax Division Directive No. 86-59
(October 1, 1986), available in
Criminal Tax Manual, Chapter 3
.
IRS Direct Referrals for Prosecution.
In limited categories of cases, the Tax Division authorizes the IRS to refer certain matters arising under the internal revenue laws directly to the United States Attorney’s Office for prosecution.
See
JM 6-4.243
. In turn, the Tax Division authorizes the United States Attorney’s Office to conduct grand jury investigations into these matters, to the extent necessary to perfect the charges that the IRS has directly referred.

[updated June 2020] [cited in
JM 6-4.212
]

## Nearby sections

- [Justice Manual § 6-4.010 Federal Criminal Tax Enforcement](https://www.frixlaw.com/law-library/statutes/JM_S6-4.010.md)
- [Justice Manual § 6-4.011 Criminal Tax Manual and Other Tax Division Publications](https://www.frixlaw.com/law-library/statutes/JM_S6-4.011.md)
- [Justice Manual § 6-4.110 IRS Administrative Investigations](https://www.frixlaw.com/law-library/statutes/JM_S6-4.110.md)
- [Justice Manual § 6-4.120 Grand Jury Investigations—Generally](https://www.frixlaw.com/law-library/statutes/JM_S6-4.120.md)
- [Justice Manual § 6-4.121 IRS Requests to Authorize Grand Jury Investigations](https://www.frixlaw.com/law-library/statutes/JM_S6-4.121.md)
- [Justice Manual § 6-4.122 United States Attorney's Grand Jury Investigations and Prosecutions](https://www.frixlaw.com/law-library/statutes/JM_S6-4.122.md)
- [Justice Manual § 6-4.123 Joint United States Attorney—IRS Request to Expand Tax Grand Jury Investigation](https://www.frixlaw.com/law-library/statutes/JM_S6-4.123.md)
- [Justice Manual § 6-4.125 IRS Transmittal of United States Attorney's Recommendation, Special Agent's and Criminal Tax Counsel's Reports, and Exhibits from Grand Jury Investigation](https://www.frixlaw.com/law-library/statutes/JM_S6-4.125.md)
- [Justice Manual § 6-4.126 Restriction on Disclosure of Grand Jury Matters to IRS for Civil Use](https://www.frixlaw.com/law-library/statutes/JM_S6-4.126.md)
- [Justice Manual § 6-4.130 Search Warrants](https://www.frixlaw.com/law-library/statutes/JM_S6-4.130.md)
- [Justice Manual § 6-4.200 Tax Division Jurisdiction and Procedures](https://www.frixlaw.com/law-library/statutes/JM_S6-4.200.md)
- [Justice Manual § 6-4.209 Stolen Identity Refund Charges](https://www.frixlaw.com/law-library/statutes/JM_S6-4.209.md)
- [Justice Manual § 6-4.210 Tax-Related Mail, Wire, or Bank Fraud, RICO, or Money Laundering Charges](https://www.frixlaw.com/law-library/statutes/JM_S6-4.210.md)
- [Justice Manual § 6-4.211 Standards of Review](https://www.frixlaw.com/law-library/statutes/JM_S6-4.211.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/JM_S6-4.122. Check the current official text before relying on it. Not legal advice.
