Case Results

$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).

$15,000,000 trust fund liability case - Taxpayer settled with IRS for $2,000,000. Nonreported case (2014).

$1,200,000 trust fund liability (employment tax) case - Total Taxpayer victory after jury trial. (Approx. 2008). (Taxpayer awarded approximately $80,000 in attorney fees from the United States)

$1,050,000 case where IRS disallowed Taxpayer's net operating losses and included $1,200,000 of debt cancellation in income. IRS Appeals Office settled with Taxpayer. Taxpayer owed nothing and was due a $33,000 refund (2015).

$1,000,000 penalty claimed by IRS for failure to file/failure to pay taxes - IRS Appeals Office abated the penalty. (2012)

IRS claimed Taxpayer did not qualify for sale of principal residence exclusion and owed approximately $135,000 - United States Tax Court found Taxpayer owed approximately $15,000 in taxes. Wickersham, T.C. Memo 2011-178 (2011). (Note: The accounting firm which improperly prepared Taxpayer's return paid over $27,000 for Taxpayer's attorney's fees.)

In excess of $2,000,000 in tax liability claimed by IRS considering rollover effect of decision. United States District Court found Taxpayer owed nothing. (Approx. 1981)

IRS claimed Taxpayer owed $4,000,000+ in taxes relating to a retirement plan and insurance – IRS Appeals Office 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)

IRS claimed Taxpayer owed in excess of $1,000,000 plus a fraud penalty. Case was reviewed by IRS counsel and the fraud penalty was conceded. Any taxes paid were recouped with the carrybacks, although interest had to be paid. (2014)

IRS claimed Taxpayer owed in excess of $1,000,000 for cancellation of debt and gain. Case was resolved with the IRS for $61,000. (2015)

Numerous innocent spouse cases have either been successfully resolved or tried, with the innocent spouse owing no taxes. (1985 to date)

Numerous offers in compromise have been resolved with the IRS if case warrants offer in compromise treatment.