Our client had a previous criminal tax conviction as she pled guilty to two counts of filing a false tax return pursuant to Internal Revenue Code § 7206(1).
When the case was returned to the Internal Revenue Service (IRS) civil division the IRS claimed that our client owed over 3 million dollars in tax, interest, and a tax fraud penalty pursuant to Internal Revenue Code § 6663.
The Solution:After our tax lawyers filed a petition with the United States Tax Court the IRS agreed to reduce the amount due to less than $150,000 plus accrued interest.
A small food supply company owed the IRS over $400,000 for allegedly intentionally failing to file in IRS Form 8300 which is used to report cash payments over $10,000, and the IRS was threatening to levy on our client’s bank accounts, and other assets.
The Solution:We obtained a stay of IRS’ collection action by arguing that the IRS had not properly afforded our client appeal rights. We then convinced the IRS that any errors by our client may have been careless, but not intentional. The IRS reduced the penalty to less than $1,200.
Our client pled guilty to criminal tax charges of filing false income tax returns with the California Franchise Tax Board. The FTB demanded restitution payments of almost $100,000.
The Solution:We successfully negotiated with the criminal investigation division of the FTB to reduce the restitution payment to approximately $40,000, even though the FTB criminal special agent had previously told the client’s criminal attorney that no reduction was possible.
Our client was assessed California payroll taxes by the California Employment Development Department (EDD) for over $300,000, including a fraud penalty for an 8- year period.
After a two-day hearing before an administrative law judge of the California Unemployment Compensation Appeals Board the EDD conceded the case and issued a refund check for approximately $9,000.
As a result of a conviction of criminal tax fraud by the State of California Franchise Tax Board, our client, a doctor owed over $500,000. Although he was not eligible for an offer in compromise, we successfully brought a lawsuit against the FTB and settled for less than $100,000.
Our clients had purchased a property many years ago and had substantially remodeled and added to the home built thereon, but over the years had lost or misplaced many of the documents evidencing the remodeling and addition costs.
An FTB tax audit asserted substantial deficiencies related to the determination of our clients' basis in their former home.
the FTB alleged that false documents had been submitted to it, prior to our tax attorneys being involved.
The Solution:Our tax attorneys were able to avoid any criminal prosecution of the clients and dissuade the FTB from imposing a civil fraud penalty.
Our tax lawyers also obtained a significant reduction in the tax deficiency amount asserted in the FTB's Notice of Action.
Our client was accused by the California Employment Development Department (EDD) of having filed fraudulent employment returns. Our tax problem lawyers convinced the EDD that their accusation was incorrect.
These statements do not constitute a guarantee, warranty, or prediction regarding the outcome of your legal matter.