IRS Tax Controversy

Outcome: Tax and Penalty Abatement

Description: IRS alleged client's business was a hobby and not engaged in for profit. All items declared by client as deductible expenses were disallowed. IRS assessed additional tax and penalties and issued a Notice of Deficiency. Client filed Tax Court petition to contest the assessments. During pretrial meetings and after application of the law to the client's favorable facts, all tax, penalties and interest were abated and client prevailed completely.