Success Stories

Federal, Out-Of-State and Foreign Tax Matters

IRS audits and appeals

  • $10 million Successfully defended a client's business loss deductions before the IRS.
  • $166,000 Savings from a client's successful IRS audit.
  • $175,000 Savings from an IRS audit reconsideration request.
  • $16,000 Savings in taxes and penalties by obtaining a "no change" audit determination.
  • $80,000 Saved by working with IRS appeals in a complex real estate investment property transaction.
  • $250,000 Successful reduction by arguing the Cohan Rule where documentation was no longer available to substantiate expenses during an income tax audit.
  • $1.8 million Abated in tax, penalties and interest through an IRS audit reconsideration.
  • $70,000 Reduction of a client's tax liability through the IRS's audit reconsideration process.
  • $265,000 Negotiated a reduction in income tax and penalties through an IRS appeal.
  • $620,000 Saved by resolving a complex partnership basis calculation dispute in an IRS audit.
  • $200,000 Saved by successfully obtaining a "no change" audit report.
  • $490,000 Conceded by the IRS for taxes and penalties in a case involving whether the taxpayer was a real estate professional for the three-year period at issue.
  • $300,000 Reduction by establishing an erroneous assessment by the IRS.

Business and employment tax matters

  • $50,000 Reduction from an assessment involving a wage and hour complaint due to alleged meal break violations.
  • $900,000 Abated in IRS penalties related to delinquent employment taxes. The business was allowed to remain open and pay the delinquent taxes through an installment agreement.
  • $1 million Successfully removed payroll tax penalties for a business client.
  • $4.7 million Saved in audit adjustments for a partnership, with no tax consequences to the two business partners.
  • $7 million Successfully defended an IRS Trust Fund Recovery Penalty assessment.
  • $48,600 Prevailed in an appeal for dismissal of a citation and assessment from a DIR-DLSE Workers' Compensation Citation.

Negotiated settlements

  • $57,000 Client savings after successfully negotiating a Tax Court case with IRS counsel.
  • $100,000 Successfully negotiated with the IRS to settle two Tax Court cases and reduce the client's tax liability.
  • $398,000 Savings from successfully negotiating a settlement with IRS counsel prior to trial.
  • $1 million Reduced assessment by settlement with IRS counsel for $6,200.
  • $5 million Settled a multimillion-dollar case set for trial in the U.S. Tax Court in which the IRS conceded adjustments in a complex series of IRC Section 1031 transactions.
  • $200,000 Savings by successfully negotiating an offer in compromise with the IRS for under $20,000 on these liabilities.
  • $100,000 Successfully resolved a case before trial in the U.S. Tax Court, resulting in a concession of tax and a refund of more than $10,000.

Innocent spouse petitions

  • $165,000 Saved for a client by prevailing in an IRS innocent spouse petition.
  • $190,000 Successfully convinced the IRS to withdraw a levy of funds for an innocent spouse.
  • $3 million Obtained innocent spouse relief for a client from a tax determination disallowing deductions.
  • $180,000 Savings in tax and receipt of a refund through a successful innocent spouse relief claim with the IRS Appeals Office.

Federal estate taxes

  • $1 million Obtained an IRS Private Letter Ruling finding favorable treatment for the taxpayer and her entities.
  • $4 million Represented the executor of an estate of a deceased tax protester to resolve all federal, state and local tax liens for a profitable result to the estate's heirs.
  • $132,000 Savings from successfully defending a client's estate in a tax audit, resulting in an IRS refund.

Federal tax penalties

  • $920,000 Resolved a U.S. Tax Court case prior to trial, resulting in no tax deficiencies or penalties for the two years at issue.
  • $100,000 Obtained complete abatement of late filing and payment penalties based on the assertion of reasonable cause.
  • $33,000 Successfully removed all penalties and reduced a client's IRS tax liability.
  • $32,000 Successfully obtained penalty relief from the IRS due to reasonable cause.
  • $85,000 Resolved a federal income tax penalty appeal.
  • $225,000 Saved by arguing that a late-filed IRS Form 982, Reduction of Tax Attributes Due to Discharge of Indebtedness, should be accepted by the IRS.
  • $476,000 Successfully abated penalties for failure to file foreign trust information returns.
  • $75,000 Obtained penalty abatement and a refund from the IRS.

Foreign and offshore tax cases

  • $60,000 Successfully obtained an agreement with the IRS to reduce penalties in a client's offshore compliance case.
  • $60,000 Refunded to our client by resolving a Tax Court case involving civil fraud penalties related to unreported offshore account income.
  • $40,000 Obtained complete civil penalty relief for clients who faced penalties related to errors on late-filed foreign trust returns.

California State Tax Matters

California Franchise Tax Board (FTB) matters

  • $172,000 Successfully defended the source of retirement income during an FTB audit.
  • $9 million Saved in an FTB tax audit.
  • $44,000 Successfully reduced in a client’s FTB audit.
  • $400,000 Saved by advocating for a 55 percent reduction in an FTB settlement.
  • $327,000 Conceded by the FTB in a tax audit.
  • $375,000 Obtained a concession in an appeals conference in a real estate professional case.
  • $93,000 Negotiated the withdrawal of a Notice of Proposed Assessment by the FTB.
  • $278,000 Fully conceded by the FTB for a client facing a proposed assessment of state income tax.
  • $700,000 Saved for a California client's state income tax audit.
  • $80,000 Successfully argued a client was not responsible for a dual determination in a sales tax audit, saving the client tax, interest and penalties.

Residency issues

  • $42,000 Settled a residency audit for an out-of-state client.
  • $52,000 Successfully obtained an abatement of California income tax for a nonresident.
  • $2.5 million Concluded an FTB residency audit with a "no change" result.

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

  • $119,000 Successfully convinced the BOE to completely reverse a dual determination.
  • $65,000 Successfully negotiated a BOE settlement of an assessment for personal liability.
  • $300,000 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.
  • $110,000 Successfully convinced the BOE to completely withdraw a determination of personal responsibility for sales and use tax.
  • $250,000 Successfully resolved a responsible person case with the BOE by compromising an assessment for a fraction of the original alleged liability.
  • $1.2 million Effectively represented an out-of-state client against the California State Board of Equalization in a use tax audit.

California Offers in Compromise

  • $60,000 Successfully negotiated an offer in compromise with the CDTFA.
  • $28,000 Successfully negotiated an offer in compromise with the CDTFA.

California Employment Development Department (EDD) matters

  • $255,000 Convinced the EDD Collection Division to reduce an assessment for personal liability and to remove all personal liens associated with the liability.
  • $400,000 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.
  • $100,000 Successfully negotiated an EDD offer in compromise for a 50 percent reduction of liability.
  • $1.7 million Convinced the EDD to reduce an original assessment of a California employer to less than $330,000, for an assessment which included wages for corporate officers and related penalties.
  • $900,000 Represented a California tech company in its EDD Petition for Redetermination.
  • $700,000 Successfully convinced the EDD to release two tax liens.
  • $80,000 Convinced the EDD to reduce a finalized EDD assessment.
  • $4.6 million 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.

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

  • $57,000 Successfully defended the classification of contract attorneys in a CUIAB petition hearing.
  • $40,000 Successfully defended a California dance studio's use of independent contractor instructors on appeal before the CUIAB, reversing the EDD's assessment.
  • $48,600 Prevailed in an appeal of a DIR-DLSE Workers' Compensation Citation, resulting in the dismissal of a citation and assessment.