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…
IRS Criminal Investigation Closed — No Prosecution
Early intervention matters in IRS criminal investigations! Our firm was recently notified that our client (an Orlando, Florida taxpayer) was no longer the target of an IRS criminal investigation. No charges were filed, no prosecution occurred, and the matter was closed. This outcome was the result of early intervention, disciplined advocacy, and a proactive defense strategy implemented before the case reached a critical point. The client, a tax professional and…
Criminal Tax Case Involving Aircraft Purchases and Tennessee Use Tax Dismissed
DeWitt Law recently represented a taxpayer indicted in Benton County, Tennessee, for alleged failure to report and pay Tennessee sales and use tax related to multiple aircraft purchased out of state. The Tennessee Department of Revenue alleged that the aircraft were brought into Tennessee without proper tax reporting, leading to a criminal tax prosecution. Our firm thoroughly analyzed the state’s evidence, tax assessments, and the taxpayer’s compliance record. Through strategic…
8th Consecutive Rating by Super Lawyers Rising Stars in Tax Practice Area
For the eighth consecutive year, Tyler DeWitt has been selected by Super Lawyers as a Rising Star in the Tax practice area. No more than 2.5 percent of lawyers in each state are named to the Rising Stars list. Super Lawyers selects attorneys using a patented multiphase selection process. Peer nominations and evaluations are combined with independent research. Each candidate is evaluated on 12 indicators of peer recognition and professional…