$5,000,000 IRS transferee liability case - The United States Tax Court ruled in Taxpayer's favor. Total Taxpayer victory, plus IRS paid $180,000 in attorney fees. Griffin, T.C. Memo 2011-61 (2011).
All cases are different and involve an analysis of the facts and law. Clients are kept informed of the status of their case and make the ultimate decision whether to settle or try the case. Obviously we will provide our input and opinions. Strategy plays an important part in the successful resolution of your case. Your input is vital in developing a successful strategy. There is no guarantee of success in any case, but we do promise that your case will be thoroughly worked, researched and prepared, and you can have input on how your case is handled. Past case results do not indicate the outcome of your case - case results are not typical.
$15,000,000 trust fund liability case - Taxpayer settled with IRS for $2,000,000. Nonreported case (2014).
$1,200,000 trust fund liability case - Total Taxpayer victory after jury trial. (Approximately 2008).
$1,050,000 case where IRS disallowed Taxpayer's net operating losses and included $1,200,000 of debt cancellation income. IRS appeals office settled with Taxpayer. Taxpayer owed nothing and will receive a $33,000 refund (2015).
$1,000,000 penalty claimed by IRS for failure to file/failure to pay taxes - IRS appeals abated the penalty. (2012)
$135,000 case - IRS claimed Taxpayer did not qualify for sale of principal residence exclusion - United States Tax Court found Taxpayer owed approximately $15,000 in taxes. Wickersham, T.C. Memo 2011-178 (2011).
Approximately $2,000,000 in tax liability claimed by IRS considering rollover effect of decision. United States District Court found Taxpayer owed nothing.
IRS claimed Taxpayer owed $4,000,000+ in taxes - retirement plan and insurance - Appeals settled case for $1 ,700,000. (2014)
IRS claimed Taxpayer owed in excess of $750,000 due to day trading. IRS ultimately settled for $25,000. (2013)
IRS claimed Taxpayer owed in excess of $1 ,000,000 from disallowed passive and hobby losses. IRS settled case for $50,000 and Taxpayer recouped the $50,000+ in later years. (2012)