Below are some of the cases our firm has handled.* While each attorney focuses on a particular area of law, we have as a firm handled a wide variety of cases.
*Prior results do not guarantee a similar outcome. Each case is unique and its outcome depends on its specific facts. While we never guarantee any particular outcome, we promise to exert our best efforts.
Voluntary disclosure and reasonable cause abatements of several hundred undisclosed offshore accounts located all over the world — Canada, Mexico, Panama, Argentina, Colombia, U.K., Switzerland, Isle of Man, India, S. Korea, China, and a number of other countries.
Settled $50,000 of Sec. 6038 penalties imposed on an individual owner of a Panamanian corporation for the failure to file Forms 5471 for $5,000.
Settled a tax court Sec. 911 exclusion case for defense contractor reducing U.S. income tax liability in excess of $70,000 to $0.
After representing himself in an audit, client received a $390,000 tax and penalty assessment. We reduced it to $38,266.
No change for IRS audit involving $300,000 of Sec. 41 research tax credit claims for architect firm.
Settlement of nearly $250,000 tax debt for less than $2,000 through an offer in compromise doubt as to collectability.
IRS partial payment agreement for nearly $2,000,000 in income tax and employment tax debt for $2,500/mo over the remaining collections statute (less than 5 years remaining).
Established self-directed 401(k) plan to carry out land investment via a joint venture arrangement.
Advised medical doctor on the tax consequences of multi-million dollar medical business sale.
Resolved IRS audit for individual real estate investor involving in excess of $500,000 of Sec. 469 passive activity loss carryforwards.
Settled IRS employment tax audit to terms favorable to client where transportation company failed to pay reasonable compensation.
Structured stock redemption transaction for materials handling company.
Prepared recertified refund claim that the IRS had previously checked in and failed to process, resulting in a refund of tax after the statute of limitations for filing a refund claim.
Advised oil and gas equipment company on avoiding dealer status and capital gain treatment.
Advised pharmacy on accounting method change to more accurately capture inventory costs.
Persuaded revenue officer not to impose Sec. 6672 trust fund penalties for son involved in father’s business.
Advised mid-sized accounting firm on choice of entity given owner differences and past tax treatment.
Convinced state tax commissioner to not impose income tax on multi-million dollar income earned by NFL player no longer domiciled in the state.
Resolved audit of $115,000 of Sec. 41 research tax credit claims for tool and die company for $105,000 of credits allowed.
Advised U.S. entrepreneur on multi-million dollar foreign joint venture structure.
Advised group of doctors involving tax implications of multi-million dollar medical business lawsuit settlement.
Settled Sec. 104 minister housing allowance for a for-profit church resulting in minimal tax due.
Advised video game developer on treatment of qualified expenses for Sec. 41 research tax credit.
Advised NFL player on state income tax consequences of multi-million dollar signing bonuses.
Advised defense contractor on multi-million dollar tax exposure from business transaction implemented by prior advisors.
Represented electric contractor facing multi-million dollar income tax liability for lack of records for supply purchases, resulting in no change and a tax loss carryforward.
Advised self-directed IRA owner on tax resulting from custodian incorrectly reporting a complete distribution.
Obtained innocent spouse equitable relief for wife who lived with her husband in a separate property state, while husband was pursuing bankruptcy relief for his share of the joint liability.
Advised well-known music group on tax structure and documentation for its U.S. and foreign touring activities.
Advised client on avoiding significant double year IRA rollover consequences.