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Henry Daniel Lively

Henry Lively’s Legal Cases

10 total

  • U.S Tax Court Controversy Case

    Practice Area:
    Tax
    Outcome:
    Reduced Tax Liability over $2,000,000
    Description:
    Client was assessed a tax liability of over $2,000,000 for various real estate development transactions. The tax liability was eventually reduced over $2,000,000 at the United States Tax Court.
  • Net Operating Loss Carryback

    Practice Area:
    Tax
    Outcome:
    Obtained in excess of $400,000 refund
    Description:
    Carried back a net operating loss for a client and they received a refund in excess of a $400,000.
  • Audit of Client's Schedule C

    Practice Area:
    Tax
    Outcome:
    Client received a "No Change" (zero adjustment)
    Description:
    Client was audited by the IRS and was issued a 30 day letter for $40,000 in taxes, interest, and penalties. We represented the client and eventually received a "no change" result for the matter.
  • Audit of Client's Schedule C

    Practice Area:
    Tax
    Outcome:
    No change for Taxpayer
    Description:
    Client was audited for the second time in two years on a schedule C. Annual revenues approximately $1 Million. IRS reviewed Revenue, Cost of Sales and various expenses. Audit was resolved within 30 days with a no change (zero adjustment)
  • Appeal of Responsible Party Liability for Sales Taxes

    Practice Area:
    Tax
    Date:
    Jun 01, 2011
    Outcome:
    Held for Petitioner (Our Client)
    Description:
    Our client was initially held liable for approximately $400,000 of Sales Tax Liability in a Tax Controversy matter almost 8 years after he left the employment of his company as the Chief Financial Officer. We appealed the case citing why, even though our client was a responsible party, he did not have control of the funds and could not direct their payment.
  • Negotiated Short Sale of Client's Property

    Practice Area:
    Tax
    Date:
    Sep 30, 2011
    Outcome:
    First and Second Trust Deed Holder Agreed to do the Short Sale.
    Description:
    Client had a property with a first and second trust deed that could not be paid in full upon the sale of the property to an outside third party. I negotiated the short pay, determined the tax implications of the sale, and negotiated the possible deficiency away.
  • Confidential v. Commissioner of Internal Revenue Service

    Practice Area:
    Tax
    Date:
    Jan 16, 2012
    Outcome:
    IRS conceded that activty was active and taxpayer had basis for his losses.
    Description:
    Represented Taxpayer in United States Tax Court case whereby the government alleged that the taxpayer was a passive rather than active investor and that he did not have basis to take losses over numerous years for his entity.
  • Confidential v. Commissioner of Internal Revenue Service

    Practice Area:
    Tax
    Date:
    Jan 06, 2012
    Outcome:
    Case was settled reducing the liability to a fraction of what the auditor claimed was due.
    Description:
    Represented client in case where IRS alleged the client provided no supporting documentation for cost of sales and numerous expense items when they were audited. Petition was filed in the United States Tax Court taking the position that these documents were provided, but they were not reviewed at the audit level.
  • Confidential v. Commissioner of Internal Revenue Service

    Practice Area:
    Tax
    Date:
    Apr 06, 2012
    Outcome:
    Approved Offer in Compromise
    Description:
    Received approval from IRS to lower clients tax bill in an Offer in Compromise by approximately $400,000 on a $650,000 tax liability with the taxes to be paid over 24 installments.
  • Condfidential v. Commissioner of Internal Revenue

    Practice Area:
    Tax
    Date:
    Nov 30, 2012
    Outcome:
    "No Change" for the taxpayer
    Description:
    Basis issue with regard to stocks transferred between stock brokerages.