TAX CONTROVERSY
Advisor to individuals and businesses seeking to resolve federal and state tax liabilities, including tax amnesty programs, offer in compromise, installment agreements and release and subordination of tax liens.Advisor to individuals and businesses in tax controversy matters involving: franchise, income, estate and gift, replacement, sales, and use taxes.Handled tax refund claim for client for claim of right involving the partial repayment of purchase price on sale of business.Handled tax refund claim for client on cancellation of debt income for S corporation that allowed a client to claim additional tax losses.Handled numerous offers in compromises for clients to settle tax deficiencies ranging from 10 cents on the dollar up to 40 cents on the dollar.Representation of former top executive of billion-dollar commercial real-estate investment management firm prosecuting treatment of income against Internal Revenue Service.Representation of legal and tax professionals prosecuting and defending against claims involving development and sale of tax preparation services and strategies. Handled examination and appeals cases for a multimillion-dollar refund claim.Litigated proper tax treatment of executive’s structured compensation payments.Litigated inadequacy of deductions taken by S corporation on behalf of shareholder.Established favorable tax cost basis in property in contest with Internal Revenue Service.Litigated appropriate computations of depletion deductions for client’s mineral deposits.Successfully contested Internal Revenue Service denial of qualified research expense deductions.Litigated deductibility of various business expenses.Successfully defended against Internal Revenue Service allegations of inadequate corporate capitalization and disguised dividends.Resolved contested valuation matters in estate and gift tax reviews.Represented numerous estates in audits of federal estate tax returns.
