Resolution of Unfiled Federal Income Tax Returns Resulting in Substitute Tax Returns

Taxpayer failed to file federal income tax returns for several years despite earning substantial self-employment income. The IRS filed substitutes for return (“SFR”) and a Notice of Deficiency, assessing tax. DeWitt Law represented the Taxpayer and challenged the tax assessment in U.S. Tax Court. The SFR returns were set aside and the IRS accepted reconstructed tax return filings. The SFR assessment was reversed and the Taxpayer paid the balance due…

IRS Audit Involving Re-Constructed Expenses – No Additional Tax Assessed

Represented self-employed contractor in field audit covering a 3-year period. Client had limited records so business mileage, supplies, and contract labor expenses had to be re-constructed. The IRS proposed a six-figure tax assessment in its original audit report. Case was appealed and the IRS reversed virtually all of the proposed assessment, allowing the re-constructed expenses.