IRS Due Diligence Audit – No Penalties Assessed
Represented tax preparer and owner of tax preparation franchise who was audited by the IRS for compliance with tax preparation due diligence rules. The IRS proposed penalties against Client in the amount of $60,840 for alleged violations. DeWitt Law appealed and the IRS reversed the assessment to $0.
$350,000 Tax Assessment Reversed to $0
United States Tax Court – Taxpayer was audited by the IRS for tax year 2016. The IRS issued a Notice of Deficiency and assessed over $350,000 in taxes, penalties, and interest. DeWitt Law represented the Taxpayer and challenged the tax assessment in U.S. Tax Court. The assessment was reversed and the Taxpayer owed $0 in additional tax.
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.
$900,000 Tax Debt Reduced to $60,000
Represented taxpayer who owed the IRS approximately $900,000. Resulted in a recommended reduction of tax by the IRS of $60,000 through an Offer in Compromise.
Streamlined Domestic Offshore Procedures (Brazil)
A U.S. citizen (“Client”) held bank accounts and residential rental property in Brazil in excess of $10,000. Client was not aware of their U.S. tax reporting requirements for foreign assets and never reported taxable foreign income on their U.S. tax returns. Client also failed to file FinCEN Form 114 Report of Foreign Bank and Financial Accounts (FBAR). DeWitt Law represented Client before the IRS to reach full filing compliance through…