Illustrative Tax Audit Representations
Two different women received massive tax bills (over $1 million) when the IRS incorrectly recorded the credit card receipts of their employers’ businesses as their personal income using their identification numbers rather than the businesses’ numbers. The IRS tried to collect huge liabilities from these women and refused to correct the errors for more than a year because of confusion caused by an old SSN on an information return. Imagine what happened when the women tried to purchase homes and their mortgage companies discovered huge tax liens.
The Firm worked with at least five separate IRS components over the course of almost one full year to eventually persuade the IRS to correct the error and fully remove the tax liabilities and tax liens from both women’s tax accounts.
For two different taxpayers, the IRS rejected virtually all of the business expense deductions claimed by their small corporations, proposing potential additional tax liabilities and penalties totaling several hundred thousand dollars. Working with the clients' bookkeepers and accountants, the Firm developed evidence and arguments establishing the propriety of the claimed deductions.
In a matter of months, the Firm persuaded the IRS to concede virtually all of the asserted tax liabilities.
Another taxpayer called the Firm after the IRS disallowed capital losses upon the sale of a large family business and issued a notice of deficiency imposing tax liabilities and penalties totaling well into six figures, asserting that the passive activity loss rules governed. Facing a soon-to-expire statute of limitations, the Firm filed a petition in the U.S. Tax Court challenging the IRS action.
The Firm then helped the taxpayer develop documentation establishing the executive's active participation in the business. Based upon that presentation, the IRS quickly conceded the case in its entirety.
Two different women received massive tax bills (over $1 million) when the IRS incorrectly recorded the credit card receipts of their employers’ businesses as their personal income using their identification numbers rather than the businesses’ numbers. The IRS tried to collect huge liabilities from these women and refused to correct the errors for more than a year because of confusion caused by an old SSN on an information return. Imagine what happened when the women tried to purchase homes and their mortgage companies discovered huge tax liens.
The Firm worked with at least five separate IRS components over the course of almost one full year to eventually persuade the IRS to correct the error and fully remove the tax liabilities and tax liens from both women’s tax accounts.
For two different taxpayers, the IRS rejected virtually all of the business expense deductions claimed by their small corporations, proposing potential additional tax liabilities and penalties totaling several hundred thousand dollars. Working with the clients' bookkeepers and accountants, the Firm developed evidence and arguments establishing the propriety of the claimed deductions.
In a matter of months, the Firm persuaded the IRS to concede virtually all of the asserted tax liabilities.
Another taxpayer called the Firm after the IRS disallowed capital losses upon the sale of a large family business and issued a notice of deficiency imposing tax liabilities and penalties totaling well into six figures, asserting that the passive activity loss rules governed. Facing a soon-to-expire statute of limitations, the Firm filed a petition in the U.S. Tax Court challenging the IRS action.
The Firm then helped the taxpayer develop documentation establishing the executive's active participation in the business. Based upon that presentation, the IRS quickly conceded the case in its entirety.