$1,420,838 Tax Liability Reversed to $0

Taxpayer was audited by the IRS after a third-party cryptocurrency exchange reported to the IRS gross proceeds the Taxpayer received from selling cryptocurrency. The IRS proposed additional tax of $1,095,708 plus penalties of $219,142 and interest of $105,988. DeWitt Law represented the Taxpayer and challenged the assessment in U.S. Tax Court. The Court reversed the assessment in full, resulting in $0 of additional tax owed.

$275,000 Tax Liability Reversed Resulting in Refund

Taxpayer was audited by the IRS (via Notice CP2000), which resulted in a Notice of Deficiency. The IRS proposed additional tax (including penalties and interest) of $275,000. DeWitt Law represented the Taxpayer and challenged the tax assessment in U.S. Tax Court. The Court reversed the assessment, resulting in a refund.

Sale of Principal Residence

Taxpayer was audited by the IRS (via Notice CP2000), which resulted in a Notice of Deficiency. The IRS proposed additional tax of $350,685 plus penalties of $70,137 after a third party reported to the IRS proceeds from the sale of Taxpayer’s home. DeWitt Law represented the Taxpayer and challenged the tax assessment in U.S. Tax Court. The Court reversed the portion of the assessment related to the sale of the Taxpayer’s principal residence, reducing the total tax liability to only $9,527.

Reduction of Fraud Penalty

Taxpayer was audited by the IRS for tax years 2012 through 2016, resulting in a Notice of Deficiency proposing additional tax plus nearly $400,000 in fraud penalties under I.R.C. § 6663. DeWitt Law represented the Taxpayer and challenged the assessment in U.S. Tax Court. The Court substantially reduced the fraud penalties by approximately 68%.

Sale of Principal Residence

Taxpayer was audited by the IRS (via Notice CP2000), which resulted in a Notice of Deficiency. The IRS proposed additional tax and penalties of $160,164 after a third party reported to the IRS proceeds from the sale of Taxpayer’s home. DeWitt Law represented the Taxpayer and challenged the tax assessment in U.S. Tax Court. The Court reversed the assessment, resulting in a total tax liability of $0.

Professional Gambler - $350,000 Tax Assessment Reversed to $0

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.

Unfiled 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.

Audit Dispute

Taxpayer and his business were audited by the IRS for tax years 2016, 2017, and 2018. The IRS did not accept the documentation the Taxpayer provided in the audit to substantiate the business income and deductions claimed on the tax returns. A Notice of Deficiency was issued, challenging the Taxpayer's claimed business income and deductions. DeWitt Law represented the Taxpayer and challenged the tax assessment in U.S. Tax Court. DeWitt Law challenged the IRS' disallowance and argued that the substantiation provided by the Taxpayer sufficiently proved its claimed income and deductions. The case resulted in a 75% reduction of the assessment.

Barbecue Competition Case

Taxpayer's 2016 federal income tax return was audited. The IRS proposed additional tax and alleged that the Taxpayer earned hobby income from their participation in the Memphis in May Barbecue Festival. Case was administratively appealed and the IRS affirmed the proposed assessment. DeWitt Law represented the Taxpayer and challenged the tax assessment in U.S. Tax Court, arguing that the Taxpayer operated a trade or business and was entitled to ordinary and necessary business deductions. The case resulted in a 90% reduction in the tax assessment.

Equitable Spouse Claim 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.

Taxpayer Lawsuit Against the IRS

Represented taxpayer in lawsuit against the IRS seeking a $412,259.00 refund for federal income tax paid. Resulted in Entry of Default against the IRS.

IRS Lawsuit to Collect Back Taxes

Represented taxpayer in U.S. District Court (Middle District of Florida) in IRS lawsuit to collect over $500,000 in federal income tax debt. Resulted in entry of consent judgment. Judgment was satisfied for lump sum payment of $282,016.11.

Fraudulent Information Return Filings

Represented Plaintiff in U.S. District Court who filed suit under I.R.C. § 7434 against Defendants for fraudulently filing 1099 information returns with the IRS. Resulted in out-of-court settlement.

Arkansas - $300,000 Sales Tax Liability Reduced to $189,000

Represented corporation that was audited by the Arkansas DFA for additional sales tax. Challenged the DFA’s interpretation of Arkansas tax law with respect to the sale of restaurant supplies. The assessment was reduced to $189,000.  

Arkansas - $264,735 Income Tax Liability Reversed to $0

Represented taxpayer facing additional income tax assessment made by the Arkansas DFA. Challenged the assessment based on the expiration of the statute of limitations for assessment. The entire assessment was reversed to $0.

Tennessee – Full Reversal of $81,572.19in Sales & Use Tax Penalties

Represented corporation that was assessed additional sales tax and substantial penalties. Challenged the penalty assessments, resulting in a full reversal.

Tennessee – Offer in Compromise $160,150 Settled for $88,304

Represented corporation that was unable to fully pay its Tennessee sales tax liability. The liability was settled and reduced by $71,846 through an Offer in Compromise.

Tennessee – Reversal of Civil Fraud Penalty

Represented individual taxpayer who was assessed a civil fraud penalty under Tenn. Code Ann. § 67-1-1443 for alleged failure to collect, account for, and pay over Tennessee consumer use tax related to the purchase of multiple luxury vehicles. DeWitt Law challenged the fraud penalty, resulting in a full reversal.

Texas – Sales & Use Tax Assessment Reduced By $126,046

Represented corporation in defending against a sales and use tax audit initiated by the Texas Comptroller of Public Accounts. Additional sales tax was assessed and DeWitt Law challenged the assessment, resulting in a reduction of $126,046.

Gates v. Arkansas Department of Finance & Administration

DeWitt Law represented an Arkansas couple (the “Taxpayers”) before the Arkansas Supreme Court to challenge a judgment for additional Arkansas income taxes entered against the Taxpayers by the Garland County Circuit Court. The Arkansas Supreme Court held in favor of the Taxpayers by reversing the judgment and remanding the case back to the trial court.