Robert Gerald Nath's Legal Cases (4)

Tax

Trust Fund Recovery Penalty

Jun 17, 2018

OUTCOME: IRS abated the penalty in full; granted client refunds

Client was assessed $110,000 by IRS when a corporation failed to pay employees' withheld taxes. Tax law permits such assessments after investigation, as to persons "responsible" for the corporation's f ... ailure to pay over the withheld taxes. Client defended on grounds he was not responsible. We marshaled documents, declarations, and legal argument to urge abatement. Case started 2016; ended 2018

Tax

Offer in Compromise

Mar 23, 2018

OUTCOME: IRS accepted $64,000 out of $ 1 million+ owed.

Client faced more than $1 million in income tax liabilities by IRS, additional amounts at state level. Client filed Offer in Compromise. IRS accepted approx. $64,000. Client paid this amount; liens r ... eleased. Case dates: 2016-2018.

Tax

Offer in Compromise

Dec 31, 2017

OUTCOME: IRS settled for $242,000, paid over 2 years.

Client was corporation which owed $2 million+ in unpaid payroll taxes. Client filed Offer in Compromise. Cases lasted 2016-2017.

Tax

Offshore Voluntary Disclosure Program

N/A

OUTCOME: Cases resulted in acceptance by IRS of clients' voluntary disclosure and no further penalties

Numerous client matters involving IRS' Offshore Voluntary Disclosure Program (OVDP). This program encourages taxpayers with undisclosed foreign financial accounts and other property, and/or unreport ... ed income, to make a voluntary disclosure with reduced penalties. Main OVDP program has closed; "streamlined" OVDP is still in effect and active. Cases began 2009 and are ongoing.

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