When you receive that fateful letter from the IRS with proposed changes, who you pick to represent you can be worth $1,000’s of dollars. As an attorney for the IRS, I guided US Justice Department attorneys on complex tax cases. I am licensed in all Federal courts that handle tax cases, but I try to keep my cases out of these expensive forums.I just handled an IRS audit in which the IRS initially proposed a $33,468 tax deficiency. I settled the case with my client owing $14! How did I accomplish this result? In my over 35 years or private practice, I have spent many hours on IRS cases. These cases require a knowledge of the law and I believe I have an advantage as a lawyer. Furthermore, IRS personnel take me seriously since I was once an IRS lawyer. Every case is different, of course, but I believe I can make a difference.Here are some examples:
- I just handled an IRS audit in which the IRS initially proposed a $33,468 tax deficiency. I settled the case with my client owing $14! How did I accomplish this result? I got this result by doing what I learned to do when I was an IRS attorney in Washington, DC. I wrote the IRS a detailed memo laying out the facts involved and explaining the tax laws controlling the issue.
- A year ago, the IRS proposed a deficiency of more than $90,000 for one client, as the result of income the CPA failed to report on the tax return. I wrote a legal memorandum just like those I wrote when I worked for the IRS. I added proof that the unreported income was not taxable. The IRS agreed to reduce the deficiency to zero!
- Recently, the IRS proposed a deficiency of more than $12,000 plus interest and penalties. The client in 2013 exchanged a life insurance policy in one company for a new life insurance policy in another company. The former company reported over $28,000 in income to my client from this transaction. Again, I wrote a legal memorandum with cases, statutes and treasury regulations supporting my argument that the transaction was a tax free exchange of policies. The IRS agreed and removed that income. All’s well that ends well!
- Another client who sold radio advertising faced a proposed deficiency of more than $8,000. It was a tough case. The IRS questioned business expenses such as automobile mileage and business meals, for which the client had the burden of proof. Unfortunately, the client had claimed estimated figures, which she had to reconstruct. With my help, she put together the proof of her actual expenses. We brought the deficiency down to less than $1,500.
Every case is different, of course, so I cannot guarantee results like these. However, I can promise the same qualify of representation..