Success Stories

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

AgricultureIndian Tribal Income and Gaming
Amusement ParksInformation Technology
AthletesInternational Business and Corporations
AttorneysJanitorial and Cleaning Services
Auto Dealers — New CarsManufacturing
Auto Dealers — Used CarsMassage Therapists
AviationMedical Device Manufacturers
Beverage BottlersMedical Marijuana Dispensaries
Collection AgenciesMedical Technicians and Phlebotomists
Construction ContractorsNASCAR Leases
Cosmetics Manufacturers and RetailersNonprofit Organizations
Courier and Delivery CompaniesOnline Retailers
Custom Automotive FabricatorsPrivate Investigators
Dance Studios and ConservatoriesProduct Demonstrators
DentistsProfessional Gamblers
DevelopersPulitzer Prize-Winning Authors
DoctorsQualified Intermediaries (for 1031 exchanges)
Educational Materials DevelopersReal Estate Professionals
Electrical ContractorsRestaurants
Electronic Equipment InstallersRetail, Grocery and Convenience Stores
EntertainersSporting Goods Manufacturers
FarmingSteel Erectors
Foreign Financial InstitutionsTax Preparers
Gas Station OwnersTelevision Reporter and Radio Broadcasters
Government ContractorsTrucking
Grammy Award-Winning Performance Artists and ProducersWholesale Liquidation
HairdressersWineries
HospitalsYouTube Affiliates

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

Federal, Out-Of-State and Foreign Tax Matters

IRS audits and appeals

  • Our attorney successfully reduced a client's IRS audit liability, saving the client over $166,000.
  • Our attorney successfully concluded an IRS audit reconsideration, saving the client over $175,000.
  • We successfully resolved an IRS audit resulting in a "no change" determination, saving the client over $16,000 in tax and penalties.
  • Our firm successfully saved a taxpayer over $80,000, working with IRS appeals in a complex real estate investment property transaction.
  • 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 firm obtained tax, penalty and interest abatements through an IRS audit reconsideration, saving the client over $1.8 million.
  • We successfully reduced a client's tax liability by more than $70,000 through the IRS's audit reconsideration process.
  • We successfully negotiated a reduction in income tax and penalties in excess of $265,000 through an IRS audit reconsideration appeal.
  • We successfully resolved a complex partnership basis calculation dispute in an IRS audit, resulting in a tax reduction of almost $620,000.
  • We successfully obtained a "no change" audit report, resulting in a savings of over $200,000 to the taxpayer.
  • 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.
  • We quashed a summons issued by the IRS that attempted to secure the taxpayer's records from his bank.
  • One of our attorneys successfully defended a client's loss deduction before the IRS of $10 million.
  • We successfully convinced the IRS to remove an erroneous assessment, saving our client over $300,000.
  • One of our attorneys obtained a 72 percent concession from the IRS of a $1.1 million dispute over the valuation of an intangible asset.

Business and employment tax matters

  • We successfully obtained full abatement of penalties asserted against a corporation's pension plan, saving our client over $41,000.
  • 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 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.
  • We obtained an 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.
  • 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 firm successfully defended an IRS Trust Fund Recovery Penalty assessment, saving our client over $7 million.
  • Our attorney prevailed in an appeal of a DIR-DLSE Workers' Compensation Citation, resulting in the dismissal of a $48,600 citation and assessment.

Negotiated settlements

  • Our attorney successfully negotiated with the IRS to resolve a Tax Court case, eliminating the client's alleged liability of over $57,000.
  • Our attorney successfully negotiated with the IRS to settle two Tax Court cases and reduce the client's liability by $100,000.
  • Our firm successfully negotiated a settlement with the IRS outside of Tax Court, eliminating the need for trial and reducing the client's liability by over $398,000.
  • One of our attorneys settled a case assessed at over $1 million with IRS counsel for $6,200.
  • We settled a multimillion-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.
  • One of our attorneys successfully negotiated an offer in compromise with the IRS for under $20,000 on liabilities of about $200,000.
  • We negotiated a profitable settlement award for a client regarding a malpractice claim against a title company.
  • 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 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 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.

Innocent spouse petitions

  • We prevailed in an IRS innocent spouse petition, saving our client $165,000 in tax liabilities.
  • Our firm successfully convinced the IRS to withdraw a levy of funds for an innocent spouse, saving the client $190,000.
  • Our attorney obtained innocent spouse relief for a client from a tax determination involving over $3 million in contested deductions.
  • 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.

Federal estate taxes

  • 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.
  • 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.
  • Our attorney successfully defended a client's estate against identity theft, resulting in an IRS refund totaling $132,000.

Federal tax penalties

  • 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.
  • One of our attorneys successfully removed penalties in full and reduced an IRS tax liability, saving our client over $33,000.
  • One of our attorneys successfully obtained penalty relief from the IRS due to reasonable cause, saving a client over $32,000.
  • Our firm resolved a federal income tax penalty appeal, saving the client over $85,000 in penalties and interest.
  • One of our attorneys effectively convinced the IRS to abate a 75 percent civil fraud penalty.
  • 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.
  • Our attorney successfully abated $476,000 in penalties for failure to file foreign trust returns.
  • Our attorney obtained penalty abatement and a refund of over $75,000 from the IRS.
  • Our firm successfully completed a client's IRS domestic voluntary disclosure resulting in zero penalties and "no change" determinations for multiple years.

Foreign and offshore tax cases

  • 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.
  • We have assisted dozens of clients in avoiding criminal investigation and prosecution for tax crimes in connection with undeclared foreign bank accounts.
  • 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.
  • 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.

California State Tax Matters

California Franchise Tax Board (FTB) matters

  • Our attorney successfully obtained the withdrawal of an FTB proposed assessment, saving our client over $130,000.
  • We successfully defended the source of retirement income during an FTB audit, saving our client over $172,000 in tax.
  • Our firm was successful in an appeal of an FTB personal income tax determination, reducing the liability from over $61,000 to under $3,000.
  • We successfully had an assessment of more than $9 million removed from a client's account with the FTB.
  • We successfully reduced an FTB audit liability, resulting in savings for the client of over $44,000.
  • Our firm successfully convinced the FTB to reduce a proposed increase in tax by 55 percent, saving the client over $400,000.
  • Our attorney obtained a concession from the FTB, saving the client over $327,000.
  • We successfully negotiated the withdrawal of a Notice of Proposed Assessment by the FTB, saving the client over $93,000.
  • We obtained a full concession from the FTB for a client facing a proposed assessment of $278,000 in state income tax.
  • We saved a client more than $700,000 in tax during a state tax audit.
  • 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.
  • Our firm obtained a $375,000 concession in an appeals conference in a real estate professional case.

Residency issues

  • Our firm settled a residency audit for an out-of-state client, saving him approximately $42,000 in state income tax.
  • We successfully obtained an abatement of California income tax for a nonresident, saving the client over $52,000.
  • One of our attorneys concluded an FTB residency audit with a "no change" result, saving our client approximately $2.5 million.
  • We have successfully resolved collection notices and levies issued by the FTB assessed against former California residents and business owners for prior tax periods, frequently more than 20 years old.

California sales and use tax, property tax, and excise tax cases

  • One of our attorneys successfully convinced the BOE to reverse a dual determination, eliminating charges to the client totaling over $119,000.
  • Our attorney successfully negotiated a BOE settlement of an assessment for personal liability, saving the client $65,000.
  • 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 totaling over $300,000.
  • 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 BOE by compromising an assessment greater than $250,000 for a sum of $5,000.
  • Our attorney successfully negotiated a 60 percent reduction of tax on a sales and use tax case with the BOE, saving the client approximately $75,000 in tax.
  • 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 Procedure Act and federal and California Constitution. The courts ultimately granted the taxpayer its attorneys' fees.
  • 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.

California Offers in Compromise

  • We successfully negotiated an Offer in Compromise with the CDTFA, saving our client over $25,000.
  • One of our attorneys successfully negotiated an offer in compromise with the CDTFA, saving the client over $60,000.
  • Our attorney successfully negotiated an offer in compromise with the CDTFA, saving the client over $28,000.
  • We have successfully negotiated offers in compromise ranging from small accounts to a multimillion-dollar employment tax case.
  • Our attorney successfully obtained an FTB offer in compromise for a minimal amount of $800 for a client who failed to fully close a nonoperational California business, resolving several years of noncompliance.

California Employment Development Department (EDD) matters

  • We successfully convinced the EDD Collection Division to reduce an assessment for personal liability by over $255,000 and to remove all personal liens associated with the liability.
  • Our attorney successfully convinced the EDD to remove penalties for fraud or intent to evade, limit the audit to a three-year period from the original eight-year period, and reduce the original assessed amount by more than $400,000 for one of our clients.
  • Our firm successfully reduced an EDD assessment to less than $1,000 in final liability, saving the client thousands in tax, interest and penalties.
  • Our firm successfully negotiated an EDD offer in compromise for a 50 percent reduction of a liability of over $100,000.
  • 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 represented a California tech company in its EDD Petition for Redetermination, saving the company approximately $900,000.
  • We successfully convinced the EDD to release two tax liens totaling $700,000.
  • Our firm prevailed in an EDD benefits overpayment hearing, convincing the judge to overturn a benefits overpayment of more than $7,000.
  • Our attorney convinced the EDD to remove approximately $80,000 from a finalized EDD assessment.
  • 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.
  • We successfully resolved an employer's EDD liability of more than $600,000 for $120,000, following the resolution of criminal charges.

California Unemployment Insurance Appeals Board (CUIAB), and labor and employment matters

  • Our firm successfully convinced the CUIAB to reverse a 16-year-old EDD tax assessment due to improper service of the notice of assessment, saving the client over $125,000.
  • Our attorney successfully defended a client before the CUIAB, saving them over $44,000.
  • We successfully defended the classification of contract attorneys in a CUIAB petition hearing, saving the client and its independent contractors over $57,000.
  • One of our attorneys prevailed at a CUIAB benefits hearing in a worker classification dispute, helping protect a client's business model.
  • One of our attorneys successfully defended a California dance studio's use of independent contractor instructors on appeal before the CUIAB, reversing the EDD's assessment of approximately $40,000.
  • Our attorney prevailed in an appeal of a DIR-DLSE Workers' Compensation Citation, resulting in the dismissal of a $48,600 citation and assessment.

 

 

 

  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

   

 

 

 

 

 

 

These testimonials do not constitute a guarantee, warranty, or prediction regarding the outcome of your legal matter. You should consult an attorney for advice regarding your individual situation.