Tax Controversy
Our firm advises clients in areas of federal, state, and local tax law. This includes the entire Internal Revenue Service procedure from positions taken on tax returns, to audit examinations, to, if necessary, litigation in the United States Tax Court. It is our pleasure to represent clients in a wide variety of tax circumstances, which include, among other items:
Tax Controversy
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Representative Tax Controversy Experience:
- 82 percent concession by government on appeal of disallowance of $50 million in deductions claimed by publicly traded company.
- 65 percent concession by government on fraud penalty asserted against taxpayer even though taxpayer had been criminally convicted on indictment for filing false return for the taxable year in question.
- Successfully defended business owner in tax evasion case where the IRS Criminal Investigation Division accused taxpayer of not reporting one half million dollars in cash receipts.
- Successful defense of executor charged by IRS with liability for estate’s unpaid taxes.
- Achieved reversal of $2 million pension plan funding deficiency assessed against sponsor of tax qualified plan by Department of Labor.
- Exoneration of executive assessed one half million dollars in responsible person penalties.
- $50,000 settlement of estimated one half million responsible person penalty assessed against CFO.
- Two thirds concession by government relating to $600,000 responsible person assessment made against CEO.
- Several very favorable voluntary compliance and closing agreement program (“CAP”) settlements for qualified retirement plans with disqualifying features.
- Favorable settlement of reasonable compensation case.
- Several successful reasonable cause applications made for waivers of very substantial failure to deposit, non-filing, and/or late filing penalties.
- Successfully applied for 501(c)(3) tax exempt status of trust (retroactive 20 years) on behalf of a major financial institution serving as trustee.