IRS Bank Secrecy Act Investigation Closed With No Penalties
IRS Bank Secrecy Act Investigation Closed With No Penalties A Tennessee business owner received IRS letters scheduling a Title 31 Bank Secrecy Act (BSA) examination of his company. The IRS wanted to determine whether the business was operating as an unregistered money services business. The examination covered a six-month period, and the agent scheduled the initial interview at the client’s home. What we did We reviewed the IRS notices, the…
Tennessee Department of Revenue Reverses $453,220 Personal Liability Assessment Against Restaurant Co-Owner
DeWitt Law successfully obtained reversal of a proposed $453,220.13 Tennessee personal liability assessment issued against a restaurant co-owner. The Tennessee Department of Revenue initially alleged that our client was personally liable for sales tax collected by the business but not remitted to the State. After an informal taxpayer conference, the Department ruled in our client’s favor and abated the personal liability assessment in full. The hearing officer found that although…
Alabama Income Tax Assessments reversed
A client came to our firm facing multiple years of income tax assessments from the Alabama Department of Revenue, despite never living or working in Alabama during the years at issue. The situation was especially frustrating because the client had already hired another law firm to resolve the matter. Despite prior submissions and efforts, the case remained unresolved and enforcement actions continued. The state’s position was based on an incorrect…
IRS Crypto Penalty Abatement: $523,825.26 Eliminated
The ProblemOur client was assessed over $1 million by the IRS for alleged unreported cryptocurrency transactions. The assessment included substantial accuracy-related penalties under IRC §6662(a) and arrived with one of the most serious enforcement notices the IRS can issue: a Notice of Intent to Levy. At that point, the IRS had the legal authority to begin seizing assets. The taxpayer maintained that the reporting errors were not intentional and stemmed…
IRS Tax Preparer Fraud Investigation Closed With No Findings Under IRC § 6700, 6701, 6694, and 6695
DeWitt Law represented a high-volume federal income tax return preparer after the IRS opened an investigation involving potential civil penalty allegations under IRC §§ 6700 and 6701, as well as potential IRC § 6694 and 6695 return preparer violations. Immediately after being notified of the investigation, the client retained DeWitt Law to provide legal representation and early intervention. Our firm took over the matter from the outset, handled all communications…