A hospital chain in a healthcare fraud investigation following the execution of search warrants based on allegations made by a qui tax relation.An attorney in an IRS investigation of failure to file tax returns.Convinced the government that no criminal charges should be brought. Large National Corporation in investigation of potential environmental criminal violations.Numerous clients in making voluntary disclosures to the IRS regarding unfiled tax returns, substantiation tax issues and offshore activities to avoid criminal prosecution.CPA subject of an investigation by the Tax Inspector General's Office and negotiated a resolution involving no criminal charges.White Collar and Criminal Tax Controversies Representation Matters Numerous estates in IRS challenges to family limited partnerships involving IRC §§ 2703, 27 and other substance-over-form attacks.Numerous estates in IRS challenges to the valuation of closely-held businesses and estate planning vehicles fractionalizing ownership and control.Client in connection with IRS challenge to losses arising from failed tender offer for a foreign publicly-traded company.Successfully convinced court that the government could not propose penalties. Client in IRS attempt to impose penalties during litigation of civil tax matter.Owner and closely-held business in IRS examination of issues related to change in accounting method.Large public company in an IRS challenge to deduction of expenses related to merger with competitor.Numerous tax professionals under investigation for alleged ethical and IRS Circular 230 violations.Clients in IRS challenges to classification of independent contractors versus employees.Clients in IRS attempt to reclassify losses associated with horse and cattle activities as hobby losses under IRC § 183.Numerous clients in tax shelter examinations and civil litigation.Attorney in a challenge to IRS summons for records related to attorney’s client’s offshore activities.Client in IRS challenge to losses arising from investment in distressed assets.Successfully settled case for significantly less than the IRS’s proposed assessment. Estate in an IRS challenge to the value of interest in a closely-held business.Family in challenge to IRS disallowance of tax benefits and prepared imposition of penalties.Numerous clients through the IRS Offshore Voluntary Disclosure initiatives and other voluntary disclosure programs.Client in successfully resolving issues regarding unfiled payroll tax returns for multiple years.Client in a successful challenge to the IRS' attempt to retroactively apply a Treasury regulation.Fifth Circuit and successfully argued that the IRS cannot invoke a six year statute of limitations. Fifth Circuit regarding the IRS attempt to impose a substantial penalty. Supreme Court regarding the IRS attempt to invoke a six year statute of limitations. Board of Directors, Secretary and TreasurerĬivil Tax Controversies Representation Matters.Planning Committee Member, Civil Tax Controversy Program.
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