Newport Beach, CA
Tax Lawyer at Newport Beach, CA
Practice Areas: Tax, Tax Fraud & Tax Evasion
OUTCOME: Favorable to taxpayer. Affirmed by 9th Circuit.
Re-trial before U.S. Tax Court of innocent spouse appeal, involving first-impression issue of broader scope of review.
OUTCOME: Victory
United States District Court litigation involving penalty for failure to honor Internal Revenue Service levy upon bank.
OUTCOME: Dismissal favorable to client. Affirmed by 9th Circuit.
Petition to quash IRS summons involving service and jurisdiction issues.
OUTCOME: Favorable to taxpayer.
Federal district court trial of a multi-million dollar refund action involving first-impression issue of whether a qui tam relator’s prosecution of an action under the False Claims Act could constitute ... a trade-or-business activity.
OUTCOME: Dismissal favorable to client. Affirmed by 9th Circuit.
Case involving District Court jurisdiction over claim for refund where taxpayer asserted bad-debt loss exception to 26 U.S.C. § 6511(a) limitation on time to file refund claim.
OUTCOME: Favorable Judgment against principal entity. Settlement and dismissal of remaining entities.
Litigation of transferee and alter ego claims in a complicated case arising from a tax shelter, resulting in a favorable judgment against principal entity of more than $350 million.
OUTCOME: Summary judgment in favor of client. Aff'd by 9th Circuit.
Injunction case involving use of IRS information returns.
OUTCOME: Trial victory.
United States Tax Court trial involving innocent spouse relief from tax liability.
OUTCOME: Victory on all primary issues. Final issue conceded by opponent.
Successfully obtained summary judgment in Tax Court case involving deductions claimed for intellectual property.
OUTCOME: Trial victory, favorable to taxpayer.
Tax Court trial of innocent spouse issues contested by non-relieved former spouse, upholding IRS determination of tax relief to innocent spouse.
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