Results

We are committed to delivering results for our clients. We invite you to review a sample of the representative tax matters we have resolved for our clients. All cases are different and the summaries below should not be interpreted as a prediction or guarantee of success or specific results.

 

Criminal Tax & Fraud Cases

No Jail Time Imposed for Conviction Under 26 U.S.C. § 7206(2)
Represented accountant facing allegations of fraudulently preparing tax returns causing a tax loss of $2,329,255 to the government. Negotiated a plea agreement where accountant pled guilty for three felony counts of Filing, Aiding, or Assisting in Filing a False Tax Return under 26 U.S.C. § 7206(2) and the tax loss was limited to $37,125. At sentencing hearing, DeWitt Law argued for a downward departure from the guidelines sentence range of 10 to 16 months imprisonment. The Court granted the downward departure and imposed a sentence of probation with no jail time.

25 Felony Tax Evasion Charges Dismissed
Represented taxpayer facing 27 felony (and 1 misdemeanor) tax crimes. 25 felony charges and 1 misdemeanor charge dismissed. Plea agreement and pre-trial diversion granted to Taxpayer resulting in no jail time, supervised probation for 2 years, and no criminal record upon completion of diversion.

30 Felony Tax Evasion Charges Dismissed
Taxpayer indicted for 31 tax-related felony counts. 30 charges were dismissed and case was resolved through pre-trial diversion with no jail time and expungement of criminal record upon completion of diversion.

IRS Criminal Investigation Closed
Represented taxpayer investigated by the IRS for possible criminal tax violations. Investigation closed and no criminal charges filed. 

IRS Criminal Investigation - No Criminal Charges Filed
Represented taxpayer investigated by the IRS Criminal Investigation department for potential tax crimes related to over $5 million dollars in unreported bank account deposits. Investigation closed and no criminal charges filed. 

IRS Criminal Investigation Case - No Criminal Charges Filed
Represented taxpayer investigated by the IRS Criminal Investigation department for potential tax evasion through car dealership owned by Taxpayer. Investigation closed and no criminal charges filed. After the criminal investigation was closed, the IRS initiated a civil field audit for the same tax years. Represented Taxpayer in the civil audit, which resulted in $0 in additional tax.

Florida Department of Revenue Criminal Investigation Case
Represented Taxpayer in criminal investigation by the Florida Department of Revenue for alleged sales tax evasion. Investigation closed and no criminal charges filed.

TN Department of Revenue Criminal Investigation Case
Represented Taxpayer in criminal investigation by the Tennessee Department of Revenue Special Investigations Department for alleged sales tax evasion. Investigation closed and no criminal charges filed.

U.S. Tax Court Cases

$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.

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.

IRS Administrative Cases

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.

U.S. District Court Cases

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.

International Tax Cases

Disclosure of Unreported Foreign Assets Through Streamlined Domestic Offshore Procedure
Taxpayer who failed to report all foreign assets to the IRS. Taxpayer failed to report taxable foreign income on IRS forms 1040, Schedule B, Schedule D, and 8938. Taxpayer failed to report foreign financial assets on FinCEN form 114 (FBAR). DeWitt Law represented Taxpayer and submitted amended tax returns and FBARs through the IRS Streamlined Domestic Offshore Procedure. Taxpayer reached full U.S. income tax compliance.  

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