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.
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