CIVIL TAX DEFENSE

 

Since 1978, over 50 years of combined experience with state and federal tax controversy work, defending against both assessment and collection of taxes, including:

 Audits and appeals

 Audit reconsideration

 Jeopardy assessment

 Suit to reduce tax assessment to judgment and foreclose on tax liens

 Form 23C assessment issues

 VEBA

 Employee leasing

 Tax shelters, e.g., Son of Boss

 “hobby losses”

 “infinite banking”

 Domestic and foreign trust

 FBAR, offshore initiatives/amnesty, and other foreign issues

 Embezzlement income

 Delinquent returns

 Income and employment taxes / payroll taxes

 100% trust fund penalty

 Abatement of tax, penalties, and interest

 Tax liens and levies, including wage garnishments

 Innocent spouse relief

 Offers in compromise (OIC)

 Installment agreements (IA)

 Currently not collectible (CNC)

 Collection due process hearings (CDP) and appeals to the U.S. Tax Court

 Invalid assessment from faulty procedure or assessment officer without proper delegation order

 Expiration of statute of limitations

 Forfeiture

 Issues of alter ego/nominee, successor liability, and fraudulent conveyance

 Issues for individual and corporate clients of the Fifth Amendment right against self-incrimination in the face of the IRS summons or subpoena

 Appearance in response to IRS administrative summons or subpoena

 Summons litigation

 Other tax litigation before the U.S. Tax Court, federal circuit courts, and the U.S. Supreme Court.