Some of Mark's Other Results
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SOME OF MARK'S OTHER* RESULTS:
(Each case stands on its own merits. No promise or warranty of specific results in your case should be inferred from results of these past cases.)
Clients’ corporate attorney and accountant
planned a corporate restructuring and succession plan that was to be tax-free,
whereby a parent corporation would be formed, the non-operating assets of the
clients’ business corporation would be distributed to the new parent, and the
subsidiary corporation with the operating assets would be sold to a key
employee. As a result of the delays by
the attorney and accountant in implementing parts of the plan, the IRS challenged
the transaction, concluded that distributions to the parent were dividends
to the clients, and determined that a deficiency, penalties and interest in excess of
$1 million were due. The matter was referred to
Mark by a major international law firm.
Mark tried the case before the United States Tax Court and obtained a
Decision that nothing was due from the clients.
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The clients, one of whom was a CPA, underwent an IRS
tax audit for 3 tax years which they were unable to resolve. Mark took their case to Tax Court
and ultimately settled it for less than 20% of what the IRS claimed was due.
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A corporation, operating for years as a
non-profit, had never qualified as a non-profit for either state or tax (IRS)
purposes and never received a determination letter. Mark fixed their corporate records and obtained a favorable
determination letter from the IRS for their tax exempt status.
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A couple sold their home many years after the
husband had acted as the general contractor in its original construction, and
after several remodels. Almost all
records of the original cost of construction were destroyed by water damage
years before the sale, and the Franchise Tax Board didn’t accept the cost basis
of the home as claimed on the return, and asserted an increased gain and
resulting tax. Mark fought the FTB and
settled the case for under 11% of what the FTB originally claimed due.
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The IRS determined a deficiency in the clients’
taxes based primarily on challenges to amounts reported for gross sales and
cost of goods sold from their schedule C business. The IRS claimed that almost $250,000 was due (including
penalties). Mark brought the case to
Tax Court and it ultimately settled for less than $25,000.
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Unfiled tax returns?
Need to correct erroneous tax returns?
Being audited by the IRS, FTB or SBE?
Received a Notice of Deficiency?
(Call immediately to protect your rights!)
Litigating Tax or Tax-Related Issues?
Mark can help!
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