DeWitt Law Defeats IRS Civil Fraud Penalty in Tax Court
DeWitt Law successfully represented a taxpayer in U.S. Tax Court who had been assessed the civil fraud penalty under Internal Revenue Code § 6663—a 75% penalty imposed when the IRS alleges intentional fraud. The IRS claimed the taxpayer knowingly underreported income, seeking to add a significant penalty to an already large tax bill. However, our firm challenged the government’s claims, highlighting inconsistencies in the evidence and presenting a compelling defense…
$208,984 Tax Liability Reduced to $107,495 in U.S. Tax Court
Taxpayer was audited by the IRS for multiple tax years, resulting in a Notice of Deficiency proposing additional tax in the amount of $208,984. The basis for the Notice of Deficiency was disallowed Schedule C contract labor and cost of goods sold. DeWitt Law filed a Petition in U.S. Tax Court challenging the Notice of Deficiency. The Court entered a Decision reducing the tax liability by over 50% to $107,495.
$220,187.27 Tax Liability Reduced to $10,699.67 in U.S. Tax Court
Taxpayer received a Notice of Deficiency proposing additional federal income tax (plus penalties) in the amount of $220,187.27. The basis for the Notice of Deficiency was alleged unreported capital gain income from the sale of the Taxpayer’s home that was renovated. DeWitt Law represented the Taxpayer and filed a Petition in U.S. Tax Court. After completing discovery, the property’s basis was substantially increased by the IRS, resulting in a Decision…
$436,327.20 Tax Liability Reduced to $33,364 in U.S. Tax Court
After being audited by the IRS, the Taxpayer received a Notice of Deficiency proposing additional federal income tax (including penalties & interest) in the amount of $436,327.20. The basis for the Notice of Deficiency was disallowed Schedule C business expenses (including contract labor and supplies) on the Taxpayer’s 2021 and 2022 federal income tax returns. DeWitt Law represented the Taxpayer and challenged the Notice of Deficiency by filing a Petition…
$201,364.80 Tax Liability Reduced to $68,396 in U.S. Tax Court
After being audited by the IRS, the Taxpayer received a Notice of Deficiency proposing additional income tax (including penalties) in the amount of $201,364.80. In the Notice of Deficiency, the IRS disallowed deductions for Schedule E rental expenses, Section 179 expenses, and micro-captive insurance expenses. DeWitt Law filed a Petition in U.S. Tax Court challenging the Notice of Deficiency. The Tax Court entered a Decision reducing the tax liability to…