Federal (IRS) Tax Issues

Our firm is committed to delivering results for our clients. We invite you to review a sample of representative criminal tax matters we have resolved for our clients.

Offer in Compromise - $1,300,000 Tax Debt Reduced to $4,614
Represented taxpayer who owed the IRS approximately $1,300,000. Tax debt was reduced to $4,614 through an accepted offer in compromise.

Offer in Compromise - $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.

Offer in Compromise - $448,000 Tax Debt Settled for $10,000
Represented taxpayer who owed the IRS over $448,000. Tax debt was reduced by over 80% through an accepted offer in compromise. Learn more.

Innocent Spouse Relief Granted - $297,000 Tax Liability Reversed
Represented taxpayer in Innocent Spouse claim with the IRS to obtain relief from a $297,000 tax assessment. Relief granted by the IRS.

Equitable Spouse Relief Granted
The Taxpayer's former spouse was self-employed and did not make estimated payments, resulting in a significant tax liability. The Taxpayer had no involvement with the former spouse's business. DeWitt Law represented the Taxpayer before the IRS and filed a claim for equitable spouse relief. The IRS denied the claim and DeWitt Law filed a Petition in U.S. Tax Court. The court granted the Taxpayer's claim for equitable spouse relief and the tax assessment was reversed.

$5.7 Million Dollar Proposed Trust Fund Recovery Penalty Reduced to $0
Represented taxpayer facing a $5.7 million dollar trust fund recovery penalty. Appeal was filed resulting in a $0 assessment. Learn more.

Trust Fund Recovery Penalty - No Penalty Assessment
The IRS initiated a Trust Fund Recovery Penalty investigation against the Taxpayer, who was the CFO for a company with outstanding federal payroll tax debt. DeWitt Law represented the Taxpayer before the IRS to defend against assessment of the penalty, arguing that the Taxpayer was not a responsible party. The investigation was closed with no Trust Fund Recovery Penalty assessment against the Taxpayer.

No-Change Audit
Represented small business taxpayers in an IRS field audit. The IRS returned an audit report proposing no additional tax. Learn more.

Field Audit Resulting in No Additional Tax
Represented self-employed taxpayer operating a multi-million-dollar auto parts retail business in an IRS field audit. Audit resulted in no additional tax. See Image

Audit Reconsideration - Reversed Assessment
Client failed to respond to an IRS audit for tax year 2011 and $93,567 in additional tax ($168,516 with penalties and interest) was assessed. Because Client did not respond to the audit, file a timely appeal with the IRS, or file a Petition in U.S. Tax Court, the IRS took collection action against Client, including levy and garnishment. Client then hired DeWitt Law for representation. An audit reconsideration claim was filed with the IRS and the tax liability (including penalties and interest) was reversed in full. See Image

Re-Constructed Expenses
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.

Audit of Tax Preparer Resulting in No Additional Tax
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.

Unfiled Tax Returns – 6 Years Filed and Processed
Client owned a multi-million-dollar landscaping company that had not filed six years of federal income tax returns. The IRS filed substitute tax returns based off 1099-MISC forms submitted by third parties. The IRS did not deduct any business expenses, resulting in a substantial tax liability. DeWitt Law prepared and filed with the IRS all missing tax returns. Client's tax liability was reduced by over $100,000.

Unfiled Tax Returns - 10 Years Filed and Processed
Client informed DeWitt Law that they had not filed a federal income tax return since 1995. DeWitt Law prepared Client's tax returns and represented Client before the IRS to prevent levy/garnishment action while the returns were being prepared/processed and resolve all outstanding tax debt through an installment agreement.

Unfiled Tax Returns – Replacing 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 on the reconstructed tax return filings, which was approximately 30% lower than the proposed assessment.

Reversal of EFIN Termination
Represented tax preparation firm before the IRS regarding termination of the taxpayer’s electronic filing privileges. Administrative appeal was filed and the termination was reversed. Learn more.

Tax Preparer Due Diligence Penalties Reversed
Represented tax preparation firm before the IRS regarding a proposed penalty assessment for alleged violations of the Earned Income Tax Credit due diligence requirements.  Administrative appeal filed and assessment was fully reversed. Learn more.

Tax Preparer Fraud Investigation Closed
Represented tax preparer under investigation for preparing fraudulent tax returns. Investigation ended with no penalties charged and no recommendation for audit or criminal investigation. Learn more.