Prior Cases

Offers in Compromise

• A civil engineering company owed the IRS approximately $1,000,000. The case was put into currently not collectible status and no installment agreement was required. An offer in compromise was eventually accepted for $80,000 to be paid in installments over 1 year. The client was able to continue in business without any seizures.
• Our client was an accountant who owed the IRS over $500,000. We filed an offer in compromise but eventually withdrew the offer after we negotiated currently not collectable status. Eventually, the statute of limitations expired on collection of the tax and our client was not required to pay the balance owed.

US Tax Court Cases

• A client deducted tuition paid to Harvard university business school as a business expense. Prior to trial, the IRS conceded based on litigation hazards, that 75% ofthe tuition was deductible and in fact, a bona fide business expense,
• Following an audit, the IRS determnined that my client owed over $1,200,000 dollars of taxes. The IRS had disallowed the tax free nature of the transaction as a like-kind exchange. On the eve of trial, the government conceded in full and my client saved over $1,200,000.
• Following an IRS audit, handled by an accounting firm, our client, a chiropractor owed over $450,000 in additional taxes based on disallowance of business expenses. After filing in tax court, a settlement was reached with the appeals division for $53,000. My client saved close to $400,000.
• My clients were victims of the Anderson Ark abusive tax shelter. We represented them throughout the IRS process and saved them approximately $300,000 from the initial proposed assessments and disallowance of net operating loss carrybacks.

Federal District Court Cases

Unlawful Seizure of Property

• The IRS seized and sold a family farm and home in Texas. Our firm obtained a temporary restraining order from the US District Court and then represented taxpayers at trial. The Court, after consideration of the post trial briefs, ruled that the taxpayers were entitled to recover their property. This case was widely covered by national television affiliates.
• The CEO of a prominent government contractor was assessed a trust fund recovery penalty due to criminal actions by its accountant hired to oversee the finances of the company. The penalty was not assessed and the company eventually settled the case for a savings of over $325,000.

Criminal Cases

• Our clients were charged with laundering narcotics proceeds and structuring transactions to avoid reporting to the IRS. Under the federal sentencing guidelines they faced a maximum prison term of 12 years. After extensive negotiations with the US attorney's office, they served one day in jail and a period of supervised release. A $2.4 million dollar forfeiture order was settled for $100,000.
• Our client was charged with tax felonies. After negotiations with the US Attorneys office, he was allowed to plead guilty to only misdemeanor tax charges and did not serve any time in jail, only a period of home detention.
• Our client had filed false and fraudulent tax returns failing to report income of over $300,000 per year. We filed a voluntary disclosure request with the IRS and amended the returns. No criminal prosecution resulted and fraud penalties were not assessed.
• We represented a tax return preparer who the government was investigation for aiding taxpayers in filing false tax returns. After extensive negotiations, no charges were filed.

Penalty and Interest Abatements

• Our clients were partners in what the IRS classified as an abusive tax shelter. After negotiations with the appeals office, substantial interest and penalties were abated on the assessments saving our clients well over 1 million dollars.

Levy Releases

• A successful home contracting business was levied by the IRS on its bank accounts and accounts receivables and was in threat of being shut down by the government. We negotiated a release of the levies and our client was given a reasonable time to restructure its business and negotiate a settlement with the IRS. If the levies had remained in place, our client would have been forced to cease operations.