We routinely represent clients in tax return audits, administrative tax appeals and judicial tax proceedings. Below are some of the issues that we have succeeded on behalf of our clients.
Tax Controversies Sample Matters
- Prevailed on appeal of an excess of $50,000 in failure to pay and failure to file penalties for individuals whose children had extensive emergency medical expenses, causing late filing and payment by the taxpayer
- Protested innocent spouse eligibility for our client’s ex-spouse, who claimed not to have been involved in a joint tax fraud scheme in excess of $250,000, despite her signing checks and other similar factors
- Represented a partnership in a New York State partnership income tax audit for a sale of two buildings in lower Manhattan in 2014 for $559 million
- Obtained penalty abatement of $250,000 for late-filed Forms 1040 and associated late payments of tax and interest based on depression, anxiety and other mental health reasons
- Contested sales tax responsible person status for a passive owner of a New York retail business
- Negotiated resolution of a multi-year corporate audit from an initial IRS proposal of $18,500 in additional tax down to $249 of additional tax
- Obtained an installment agreement for trust fund recovery taxes in excess of $500,000 owed by an officer of a NYC business, allowing the business to continue to operate
- Prepared a protest for and obtained penalty abatement for seven years of late filed individual income tax returns for a minor whose guardian was incorrectly advised that the interest income earned on personal injury settlement proceeds would not be subject to tax
- Worked with an IRS agent on behalf of the taxpayer to delay filing of a federal tax lien on a $190,000 balance until a refinancing of one of the taxpayer’s properties could be completed, and requested an installment agreement for the balance
- Negotiated a reduction of a taxpayer’s personal tax liability to $19,000 from over $280,000; and another taxpayer’s liability to $23,000 from over $125,000, using the offer in compromise approach