Represented publicly traded company in IRS Collections Matter; Filed Collections Appeal Program Request in response to Terminated Installment Agreement; Successfully had Company’s $13,000,000 Installment Plan re-instated.

Represented individual taxpayer in amending federal income tax return to claim refund from incorrect Schedule K-1; Obtained $86,000 refund for client.

Represented individual taxpayer in U.S. Tax Court regarding Foreign Earned Income Exclusion; Obtained IRS Settlement and Decision resulting in taxpayer owing $0 tax deficiency.

Represented individual taxpayer in IRS Collections Matter; Successfully set up Installment Payment Plan with Minimum Payment amount at $1,500 less than the amount originally approved by IRS.

Represented Estate in U.S.  Tax Court regarding Substitute Return; Obtained Settlement with Chief Counsel reducing taxable income by $70,000.

Represented Taxpayer in Pro-bono matter in City of Trenton, Ohio Municipal Income Tax Assessment Dispute; Obtained settlement increasing Taxpayer’s refund by over 4X.

Represented S-Corporation and Individual Taxpayer in Indiana Tax Appeal

Settled a Taxpayer’s $130,000 Ohio Unemployment Tax Liability for $20,000 with the Ohio Attorney General’s Office . Obtained a release of lien.

Served as Special Tax Counsel regarding $1.6M of IRS Claims in Chapter 13 Bankruptcy Litigation.

Represented an aggregate group of companies in an IRS audit of $2.5M of Employee Retention Credit claims involving a PEO. Analyzed IRS’ ERC Guidance and Responded to IRS’ Draft Form 886-A, which had disallowed all $2.5M of the Taxpayer’s ERC claims. Response to Draft Form 886-A resulted in allowance of over $2.3M of the ERC claims.

Analyzed Individual Taxpayers’ Transcripts over an 8-year period, reconciled payments, transfers, and credits. After recommending a solution, recovered a $1.6M refund for Individual taxpayers that CPA had not been able to obtain.

Obtained a full abatement of a $280,000 civil penalty assessed for a publicly traded company’s failure to file Forms 5471.

Represented two Partnerships in two Collection Appeal Program requests; Obtained full abatement of $31,000 failure to file penalty for each Partnership.

Represented the Target of a Grand Jury’s Investigation of the commission of IRC Section 7201 tax evasion and the filing of an IRC Section 7296 false tax return; Successfully obtained District Court’s Denial of Federal Government’s Motion for Disclosure of Privileged Documents based the Crime-fraud Exception.

Represented Individual Taxpayer in Mail Audit regarding $855,000 disallowed Cryptocurrency Theft Loss deduction; Obtained a complete no change for the client.

Key team member in a multi-million IRS Wrongful Levy Action filed in US. District Court for the Southern District of Ohio in which we obtained a favorable settlement for our client with the Department of Justice.

Represented individual taxpayer in an IRS Appeal of a disallowed alimony deduction, resulting in a complete no-change for our client, wiping out close to $70,000 of tax, interest, and penalties.

Represented individual taxpayer in an IRS Request for Innocent Spouse Relief, resulting in the IRS’ grant of complete relief for two tax years, wiping out over $105,000 of federal tax debt for our client.

Represented individual taxpayer in Taxpayer Advocate Request, reducing $175,000 tax liability to a $9,000 refund.

Represented business in Taxpayer Advocate Request, recovering a refund in excess of $140,000.