Henderson, NV
Tax Lawyer at Henderson, NV
Practice Areas: Tax
OUTCOME: Proposed audit deficiency and penalties of $5,954,443 reduced to only $266,407.
IRS proposed tax deficiency of $4,962,036 and a penalty of $992,407. IRS attempted to use theory of equitable estoppel to force client to recognize nearly $12 million in capital gain. IRS agreed to set ... tle case before trial for $266,407 in tax and no penalty.
OUTCOME: IRS agreed to accept offer of $10,000 to compromise taxes owed in excess of $2 million. IRS Offer Division failed to accept or reject the offer within 2 years and thus it was deemed accepted by IRS counsel in tax court.
IRS agreed to accept offer of $10,000 to compromise taxes owed in excess of $2 million. IRS Offer Division failed to accept or reject the original offer within 2 years of it being submitted and thus it ... was deemed accepted by IRS counsel in tax court.
OUTCOME: Settlement in favor of taxpayers.
Case involved substantial partnerships and flow through entities. IRS proposed several million dollar increase in tax against clients, but ultimately agreed to only a $4,000 adjustment to settle case.
OUTCOME: IRS proposed over $150,000 in taxes and penalties against taxpayer for income earned by ex-spouse. IRS agreed to allow taxpayer full relief from all of the taxes and penalties pursuant to the innocent spouse provisions of IRC sec. 66(c)
IRS proposed over $150,000 in taxes and penalties against taxpayer for income earned by ex-spouse. IRS agreed to allow taxpayer full relief from all of the taxes and penalties pursuant to the innocent ... spouse provisions of IRC sec. 66(c)
OUTCOME: IRS agreed to concede the case entirely.
IRS proposed transferee liability against taxpayer in the amount of $430,000.00 for an intermediary transaction characterized by the Service as a tax shelter.
OUTCOME: Taxpayer owed nothing after going to Tax Court.
IRS incorrectly determined taxpayer liable for $200,000 in tax for sales of stock. IRS agreed to settle case for $0.00.
OUTCOME: Stipulated decision filed by Court showed $0 adjustment for taxpayers.
IRS audited taxpayers and disallowed $800,000 in bad debt deductions. Petitioned U.S. Tax Court for redetermination of tax deficiencies.
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