Success Stories

We are specialists in resolving tax disputes. In dealing with the various tax agencies, we have enjoyed many successes representing taxpayers in the following industries and occupations:

Agriculture

  

Indian Tribal Income and Gaming 

 

Amusement Parks

  

Information Technology 

 

Athletes

  

International Business and Corporations 

 

Attorneys 

  

Janitorial and Cleaning Services 

 

Auto Dealers - New Cars 

  

Manufacturing 

 

Auto Dealers - Used Cars 

  

Massage Therapists 

 

Aviation 

  

Medical Device Manufacturers 

 

Beverage Bottlers 

  

Medical Marijuana Dispensaries 

 

Collection Agencies 

  

Medical Technicians and Phlebotomists

 

Construction Contractors 

  

NASCAR Leases 

 

Cosmetics Manufacturers and Retailers 

  

Non-profit Organizations 

 

Courier and Delivery Companies 

  

Online Retailers 

 

Custom Automotive Fabricators 

  

Private Investigators 

 

Dance Studios and Conservatories 

  

Product Demonstrators

 

Dentists 

  

Professional Gamblers 

 

Developers 

  

Pulitzer Prize Winning Authors 

 

Doctors 

  

Qualified Intermediaries (for 1031 exchanges) 

 

Educational Materials Developers 

  

Real Estate Professionals 

 

Electrical Contractors 

  

Restaurants 

 

Electronic Equipment Installers 

  

Retail, Grocery, and Convenience Stores

 

Entertainers 

  Sporting Goods Manufacturers 

Farming 

  

Steel Erectors 

 

Foreign Financial Institutions 

  

Tax Preparers 

 

Gas Station Owners 

  

Television Reporter and Radio Broadcasters 

 
Government Contractors   

Trucking 

 

Grammy Award Winning Performance Artists and Producers 

  

Wholesale Liquidation 

 

Hair Dressers 

  Wineries  

Hospitals 

  YouTube Affiliates 
     

Here is a sample of the successes we have had in representing our clients:

  • Our firm successfully negotiated settlement with the IRS outside of Tax Court, eliminating the need for trial and reducing the client's liability by over $398,000.
  • We successfully obtained an abatement of California income tax for a non-resident, saving the client over $52,000.
  • Our attorney successfully reduced a client's IRS audit liability, saving the client over $166,000.
  • One of our attorneys successfully removed penalties in full and reduced an IRS tax liability, saving our client over $33,000.
  • Our attorney successfully concluded an IRS audit reconsideration, saving the client over $175,000.
  • One of our attorneys successfully convinced the BOE to reverse a dual determination, eliminating charges to the client totaling over $119,000.
  • Our firm successfully defended an IRS Trust Fund Recovery Penalty assessment, saving our client over $7 million.
  • We successfully reduced an FTB audit liability, resulting in savings for the client of over $44,000.
  • One of our attorneys had success in an income tax audit, saving a client approximately $250,000 in income tax, arguing the Cohan rule where documentation was no longer available to substantiate expenses.
  • Our attorney successfully obtained an FTB Offer in Compromise for a minimal amount of $800 for a client who failed to fully close a non-operational California business, resolving several years of non-compliance.
  • Our firm successfully convinced the FTB to reduce a proposed increase in tax by 55%, saving the client over $400,000.
  • We successfully resolved an IRS audit resulting in a "no change" determination, saving the client over $16,000 in tax and penalties.
  • One of our attorneys concluded an FTB residency audit with a "no change" result, saving our client approximately $2.5 million.
  • Our attorney convinced the EDD to reduce an original assessment of a California employer from over $1.7 million to less than $330,000, for an assessment which included wages for corporate officers and related penalties.
  • Our firm obtained tax, penalty, and interest abatements through an IRS audit reconsideration, saving the client over $1.8 million.
  • One of our attorneys successfully obtained penalty relief from the IRS due to reasonable cause, saving a client over $32,000.
  • Our attorney obtained a concession from the FTB, saving the client over $327,000.
  • Our firm resolved a U.S. Tax Court case prior to trial, resulting in no tax deficiencies or penalties for the two years at issue, saving the business over $920,000 in tax, penalties, and interest.
  • One of our attorneys obtained complete abatement of late filing and payment penalties on the ground of reasonable cause, saving the client nearly $100,000.
  • Our firm represented a California tech company in its EDD Petition for Redetermination, saving the company approximately $900,000.
  • Our attorney resolved a Tax Court case involving civil fraud penalties related to unreported offshore account income, and obtained a refund for the client of over $60,000.
  • We successfully reduced a client's tax liability by more than $70,000 through the IRS' audit reconsideration process.
  • One of our attorneys prevailed in defense of a Wage and Hour Complaint, eliminating an assessment of nearly $50,000 for alleged meal break violations.
  • Our attorney successfully defend a client's estate against identity theft, resulting in an IRS refund totaling $132,000.
  • Our firm resolved a federal income tax penalty appeal, saving the client over $85,000 in penalties and interest.
  • We were successful in obtaining an agreement with the IRS to reduce penalties in a client's offshore compliance case, saving the client over $60,000.
  • Our firm successfully completed a client's IRS domestic voluntary disclosure resulting in zero penalties and no-change determinations for multiple years.
  • Our attorney earned a client a refund worth over $75,000 from the IRS.
  • One of our attorneys prevailed at a CUIAB benefits hearing in a worker classification dispute, helping protect a client's business model.
  • We successfully convinced the EDD to release two tax liens totaling $700,000.
  • One of our attorneys saved a client over $180,000 in tax, and earned a full refund of amounts previously paid through a successful innocent spouse relief claim with the IRS Appeals Office.
  • Our firm prevailed in an EDD benefits overpayment hearing, convincing the judge to overturn a benefits overpayment of more than $7,000.
  • Our attorney successfully negotiated a BOE settlement of an assessment for personal liability, saving the client $65,000.
  • We obtained a complete concession of more than $400,000 in taxes and $90,000 in penalties from IRS Appeals in a case involving whether the taxpayer was a real estate professional for the three-year period at issue.
  • Our firm successfully obtained a concession from the BOE without a hearing on a petition to abate all interest and refund overpayments to the client's customers totalling over $300,000.
  • We successfully argued a client was not responsible for a dual determination in a sales tax audit, saving the client approximately $80,000 in tax, interest, and penalties.
  • One of our attorneys successfully convinced the BOE to completely withdraw a determination of personal responsibility for sales and use tax of over $110,000.
  • We successfully resolved a responsible person case with the State Board of Equalization by compromising an assessment greater than $250,000 for a sum of $5,000.
  • We successfully negotiated a reduction in income tax and penalties in excess of $265,000 through an IRS audit reconsideration appeal.
  • One of our attorneys effectively convinced the IRS to abate a 75% civil fraud penalty.
  • Our attorney successfully negotiated a 60% reduction of tax on a sales & use tax case with the BOE, saving the client approximately $75,000 in tax.
  • We successfully resolved a complex partnership basis calculation dispute in an IRS audit resulting in a tax reduction of almost $620,000.
  • Our firm obtained a $375,000 concession in a face-to-face appeals conference in a real estate professional case.
  • One of our attorneys successfully negotiated an Offer in Compromise with the IRS for under $20,000 on liabilities of about $200,000.
  • Our attorney convinced the EDD to remove approximately $80,000 from a finalized EDD assessment.
  • We successfully negotiated the withdrawal of a Notice of Proposed Assessment by the FTB, saving the client over $93,000.
  • Our attorney resolved a client's $160,000 corporate income tax liability for $31,000 and the sole shareholder's personal tax liability of $77,000+ for $10,000 through an Offer in Compromise.
  • Our attorney successfully negotiated an unprecedented long-term installment agreement on an EDD assessment for payroll taxes of over $3.8 Million and abated over $800,000 in penalties for good cause.
  • One of our attorneys obtained a 72% concession from the IRS of a $1.1 Million dispute over valuation of an intangible asset.
  • Our attorney successfully removed more than $1 Million in payroll tax penalties from a client's business account.
  • Our attorney was able to resolve audit adjustments of more than $4.7 Million against a partnership, with the result of no tax consequence to the two business partners.
  • Our attorney was successful in arguing that a late-filed IRS Form 982, Reduction of Tax Attributes Due to Discharge of Indebtedness, should be accepted, which resulted in a debt cancellation deduction of more than $225,000.
  • We successfully resolved an employer's California Employment Development Department liability of more than $600,000 for $120,000, following the resolution of criminal charges.
  • Our attorney successfully abated $476,000 in penalties for failure to file foreign trust returns.
  • We successfully resolved a case three weeks before trial in the U.S. Tax Court, where the Internal Revenue Service sought more than $100,000. Instead, our attorney was able to obtain a refund of more than $10,000.
  • We have successfully resolved collection notices and levies issued by the California Franchise Tax Board assessed against former California residents and business owners for prior tax periods, frequently more than 20 years old.
  • We obtained a full concession from the Franchise Tax Board for a client facing a proposed assessment of $278,000 in state income tax.
  • Complete civil penalty relief was granted for clients who faced more than $40,000 in penalties related to errors on late-filed foreign trust returns.
  • We successfully extinguished a criminal investigation prior to indictment and facilitated the return of seized funds to a taxpayer who unwittingly made bank deposits when it appeared to be illegal structuring activity.
  • We obtained the abatement of nearly $900,000 in penalties assessed by the IRS relating to delinquent employment taxes. The business was allowed to remain open and pay the delinquent taxes through an installment agreement.
  • We saved a client more than $700,000 in tax during a state tax audit.
  • We quashed a summons issued by the IRS that attempted to secure the taxpayer's records from his bank.
  • We have successfully negotiated Offers in Compromise ranging from small accounts to a multi-million dollar employment tax case.
  • We have assisted numerous clients to halt IRS seizures of business for delinquent employment taxes.
  • One of our attorneys was lead counsel at the administrative level and co-counsel through trial and appellate proceedings up to and through the California Supreme Court in Morning Star Co. v. State Board of Equalization. The case was an ultimately successful challenge to the assessment of toxic waste fees on California corporations on the basis that the assessments violated the Administrative Procedures Act and federal and California Constitutions. The courts ultimately granted the taxpayer its attorneys' fees.
  • We obtained a full concession by the IRS to all issues in a Tax Court case challenging the Internal Revenue Service's determination that a Napa County winery's single pool, LIFO inventory valuation method was invalid, among other issues raised by the revenue agent. Having prepared extensively for trial, we were able to convince the Internal Revenue Service that it had no chance of success at trial.
  • We have assisted dozens of clients in avoiding criminal investigation and prosecution for tax crimes in connection with undeclared foreign bank accounts.
  • We settled a multi-million dollar case set for trial in the U.S. Tax Court in which the IRS conceded over $5 Million in adjustments in a complex series of IRC section 1031 transactions.
  • We successfully convinced the Chief of the Criminal Investigation Division to close an investigation against the executors of an estate before the matter was even referred to IRS Counsel.
  • We effectively represented an out-of-state client against the California State Board of Equalization in a use tax audit, saving the client approximately $1.2 Million.
  • Our attorneys have represented large out-of-state commercial clients to obtain relief from significant penalty charges.
  • We negotiated a profitable settlement award for a client regarding a malpractice claim against a title company.
  • One of our attorneys represented the executor of a $4 Million estate of a deceased tax protester to resolve all federal, state, and local liens for a profitable result to the estate's heirs.
  • We obtained an IRS Private Letter Ruling finding favorable treatment for the taxpayer and taxpayer's entities, saving the estate and entities over $1 Million.