MIAMI-The FBI executed search warrants at the offices of high-profile accountant and attorney Lewis Freeman, who frequently is picked by judges as a court-appointed receiver or trustee for troubled companies in South Florida, sources said. Freeman and the FBI weren't talking Thursday when asked about the warrants, which legal community sources said were executed late last week at the Miami and Plantation offices of Lewis B. Freeman & Partners.

The search warrants are the latest incarnation of Freeman's troubles with the federal government. Freeman sued the Internal Revenue Service in August over a $4.5-million civil assessment against him for allegedly promoting a parking deduction plan that the agency called an abusive tax shelter, according to court documents.

However, the FBI's presence indicates a criminal investigation may be under way, observers say. "When the IRS assesses someone a penalty, it's not normal to raid an office," said Fort Lauderdale tax litigator Martin Press, a partner with Gunster.

The IRS typically uses the Treasury Department to execute its search warrants. The FBI is part of the Justice Department.

The dapper Freeman is considered an expert on receiverships and speaks nationally on the topic. Information about the warrants remains sealed because criminal charges have not been filed against Freeman, a source said.

Freeman, in his lawsuit, is looking for the return of a $3,000 deposit to appeal the assessment. He has frequently tangled with the IRS on behalf of clients.

Freeman has retained criminal defense attorney Robert Josefsberg of Podhurst Orseck in Miami. Josefsberg did not return a call for comment.

Freeman's attorney in the tax matter, Charles Ruffner of Miami, says the IRS alleges the parking plan was a tax dodge because money was deducted from an employee's base salary, leaving less to tax. The IRS calculates that nearly 5,000 taxpayers used the product.

In his lawsuit, Freeman stated that he had received a legal opinion from Greenberg Traurig stating that the parking program did not violate any tax laws. Ruffner said he thought the matter had been resolved. He adds that Freeman had nothing to do with selling the plan to employers but introduced sellers and buyers to each other.

"We were kind of surprised when it came up again," Ruffner says. "I thought the IRS had dropped it. It's kind of bizarre."