Attorney Jason Neil Wiggam's Legal Cases

Tax

Georgia Voluntary Disclosure Agreement Resolves $7M Syndicated Conservation Easement State Tax Exposure

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OUTCOME: Facing $7M in GA exposure from IRS-audited syndicated conservation easements, we secured a Georgia Voluntary Disclosure, eliminated 2010–2011 liability, and obtained full penalty abatements for remaining years.

Conservation Easement Cases have continued to climb throughout 2024 at my firm, Wiggam Law. We have continued to help many clients this year while the IRS continues to crack down on these investments. ... Our client invested in Syndicated Conservation Easements from 2010 to 2014, which were all under audit by the IRS. Their total exposure to the Georgia Department of Revenue was $7,044,808. We initiated a Voluntary Disclosure Agreement (VDA) with the state of Georgia, focusing on limiting the client’s state tax exposure to only the last three tax years (2012-2014). We were able to mitigate our client’s tax liability while ensuring compliance with state tax laws. As a result, we received a full abatement of penalties for tax years 2012 through 2014, and they did not have to pay any taxes, penalties, or interest for tax years 2010 and 2011 at all.

Tax

Georgia Voluntary Disclosure Agreement Eliminates $520,269 in State Tax, Penalties, and Interest

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OUTCOME: Through a strategic Georgia Voluntary Disclosure Agreement, we eliminated three years of state tax, penalties, and interest, plus additional penalties and interest for three more years. Saving our client $520,269 and avoiding aggressive state enforcement.

Case Result: $520,269.00 Saved! Our client came to my firm, Wiggam Law, facing serious exposure with the State of Georgia after multiple years of unreported tax obligations. The uncertainty was hea ... vy. Penalties and interest had been accruing quietly in the background, and the client feared that once the state took action, the financial consequences would escalate quickly and aggressively. We stepped in to take control of the situation and bring structure to a problem that felt unmanageable. After carefully reviewing the client’s history and risk profile, our team determined that a Georgia Voluntary Disclosure Agreement offered the strongest path forward. We handled all communications with the Georgia Department of Revenue, guided the disclosure process, and strategically limited the state’s lookback period to the maximum years allowed, preserving critical protections for the client throughout. When the agreement was finalized, the impact was immediate and significant. Three full years of Georgia tax, penalties, and interest were eliminated entirely, along with penalties and interest on penalties for an additional three years. The client avoided years of unnecessary liability and saved approximately $520,269.00. This outcome highlights how a proactive strategy and experienced representation can dramatically change the course of a tax case. If you’re facing state tax exposure, don’t wait for enforcement to begin. Contact me; I am here to help!

Tax

IRS Revenue Officer Defense and Georgia Voluntary Disclosure Secure $686,802 in Federal and State Tax Penalty Relief

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OUTCOME: After IRS Revenue Officer action for unfiled returns, we filed all back returns, secured Georgia voluntary disclosure relief, and obtained near-total federal penalty abatements - saving $686,802.06 and resolving the client’s liabilities in full.

Case Result: $686,802.06 Saved! We understand that life happens, and at Wiggam Law, we’re here to protect clients from harsh tax consequences when it does. Our client came to us after receiving a ... notice from an IRS Revenue Officer about multiple unfiled tax returns. He faced significant tax exposure from large asset liquidations during the COVID pandemic. At the same time, he was battling severe mental health challenges that had gone undocumented and unaccommodated for years. We jumped into action immediately. First, we coordinated the preparation of all outstanding federal tax returns with the client’s CPA. Simultaneously, we developed and submitted a detailed Penalty Abatement Request outlining our client’s mental health conditions and how they directly contributed to his noncompliance. We also submitted a Voluntary Disclosure Request to the Georgia Department of Revenue, requesting that the DOR limit the client’s filings to the last three years and waive all his penalties. The state forgave over $93,000 in liabilities thanks to our efforts. On the federal side, we worked closely with the assigned Revenue Officer to secure full penalty abatements for every tax year except one, which we appealed. We were then successful in getting penalties for that final year abated with IRS Appeals. After that, we helped our client full pay the remaining balance, putting his tax troubles behind him. Total Liability Eliminated: $686,802.06.

Tax

IRS Collection Statute Expiration (CSED) and Georgia Offer in Compromise Save $144,000 in Federal and State Tax Liability

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OUTCOME: Client owed $279,000 to the IRS and Georgia after spousal misuse of tax funds. We leveraged IRS Collection Statute Expiration to eliminate $84,000 and negotiated a Georgia Offer in Compromise reducing $84,000 to $24,000, saving $144,000 total.

Our client owed $279,000 in federal and Georgia income taxes due to spousal misuse of funds intended for tax payments. We implemented a coordinated IRS and state tax resolution strategy. At the fede ... ral level, we leveraged the IRS Collection Statute Expiration Date (CSED), allowing $84,000 to expire and securing an installment agreement for the remaining balance. At the state level, we negotiated a Georgia Offer in Compromise, reducing an $84,000 liability to $24,000. Total tax liability eliminated: $144,000 through strategic IRS collection defense and state tax settlement negotiation.

Jason Neil Wiggam's Legal Cases (4)

Georgia Voluntary Disclosure Agreement Resolves $7M Syndicated Conservation Easement State Tax Exposure

Georgia Voluntary Disclosure Agreement Eliminates $520,269 in State Tax, Penalties, and Interest

IRS Revenue Officer Defense and Georgia Voluntary Disclosure Secure $686,802 in Federal and State Tax Penalty Relief

IRS Collection Statute Expiration (CSED) and Georgia Offer in Compromise Save $144,000 in Federal and State Tax Liability