37 YEARS TAX & AUDIT EXPERIENCE, FORMER IRS AGENT & APPEALS OFFICER
37 YEARS TAX & AUDITEXPERIENCE, FORMER IRS AGENT &APPEALS OFFICER

PRACTICE

 

 

Internal Revenue Service

Income & Payroll Tax Audits

Administrative Appeal

Installment Agreement

Lien and Levy Release

Offer in Compromise

Offshore Volunatary Disclosure

United States Tax Court Litigation

Criminal Investigation

United States Attorney's Office

Civil & Criminal Tax Representation

Tax Refund Litigation

Currency and Suspicious Activity Report Investigation


 

California Franchise Tax Board

Income Tax Audit

Administrative Appeal

Lien and Levy Release

Offer in Compromise

State Tax Court Litigation

 

State Board of Equalization

Sales Tax Audit

Administrative Appeal

Collection Matters

 

Employment Development Department

Payroll Tax Audit

Administrative Appeal

Collection Matters

 

Federal and California Department of Labor Investigations 

 

 

SIGNIFICANT TAX COURT VICTORIES

Most of our cases are settled at the audit level, in administrative appeal or with District Counsel before trial. However there were instances when the settlement offered by the IRS Attorney was unacceptable to our client, and required to litigate the issue in the United States Tax Court.

 

In Schirle v. Commissioner, Judge Vasquez agreed with our position that the IRS did not meet its burden of proof of establishing the petitioner omitted 25 percent of his gross receipts for years barred by the normal 3 year statute of limitations. Therefore, the Court agreed to bar the IRS from assessing three years of proposed penalties, interest and taxes.

 

In the Estate of Wright v. Commissioner, Judge Goeke agreed with our position and determined that the IRS was in error and excluded settlement income in the amount of approximately $1,260,000. Judge Goeke later also awarded my client her attorneys fees based on a qualified offer that I filed with District Counsel prior to trial.

Contact Us

Gary H. Kuwada

A Professional Law Corporation

601 S. Figueroa St., Suite 3460

Los Angeles, CA 90017

 

Phone: 213. 623. 5513

Fax: 213. 623. 5301

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