Success Stories

U.S. Tax Court

Client was assessed $661,617 by the IRS. Represented client in U.S. Tax Court. Case resolved with a final liability of $6,862 — a reduction of $654,755. (2025)

Client faced a potential liability of approximately $2,000,000 in an IRS audit. Audit closed with a no-change determination and $0 owed. (2023)

Client came to the firm mid-case with an existing audit finding. After taking over representation, the audit finding was reduced by an additional $150,000 beyond what the prior representative had achieved. (2023)

Client’s company owed $163,683 and client personally owed $122,253, totaling $285,936. Filed in Tax Court for each. After months of negotiations and a near-complete re-audit, company liability was reduced to $37,421 and personal liability to $13,803 — total owed $51,224, total savings $234,712. (2020)

Client was assessed by the IRS, which disallowed all business losses, resulting in a significant deficiency. Provided IRS appeals with an accurate depiction of reinstated losses. (2021)

Client was assessed $944,808.42 for one tax year. Represented client before IRS appeals. Final determination: $1,968 owed. Because the client’s bank account had already been levied for $4,600, client received a refund of $2,632. (2020)

Corporation was audited and deficiencies were found amounting to approximately $250,000 in additional tax owed. Petitioned the United States Tax Court and proved legitimate business expenses. Tax Court decision was filed with no deficiencies or addition to tax owed.

Corporation was audited and deficiencies were found amounting to approximately $750,000 in additional tax owed. Petitioned the United States Tax Court and proved legitimate business expenses. Tax Court decision was filed with a deficiency of approximately $22,000 of tax owed.

IRS Offers in Compromise

Client owed $2,477,420 to the IRS. Offer in compromise accepted at $10,000. (2023)

Client owed $2,500,000 to the IRS. Negotiated an offer in compromise reducing the liability to $450,000 — a savings of $2,050,000. (2024)

Client owed $2,000,000 to the IRS. Negotiated an offer in compromise reducing the liability to $699,000 — a savings of $1,300,000. (2024)

Client owed $120,000 to the IRS. Offer in compromise accepted at $29,999 — a savings of $90,001. (2025)

Client’s IRS tax liability reduced by $1,257,167 through negotiation. (2022)

Client’s IRS tax liability reduced by $663,264 through negotiation. (2022)

Client’s IRS tax liability reduced by $560,000 through an offer in compromise. (2022)

Client owed $143,777 to the IRS. Offer in compromise accepted at $33,000. (2021)

Client’s IRS balance reduced from $687,893 to $293,455 — a savings of $394,438. (2020)

Entity owed approximately $330,000 in back withholding taxes. Offer in compromise filed and accepted by the IRS for approximately $15,000.

State Tax Offers in Compromise & Liability Negotiations

Client owed $4,293,689.01 to New York State. Negotiated liability to $0. (2024)

Client owed $450,000 to New York State. Offer in compromise accepted at $87,000 — a savings of $363,000. (2025)

Client owed $430,000 to New York State. Offer in compromise accepted at $108,000 — a savings of $322,000. (2025)

Client owed $420,000 to New York State. Offer in compromise accepted at $33,000 — a savings of $387,000. (2024)

Client’s New York State tax liability reduced by $1,879,934.40 through an offer in compromise. (2021)

Large New York State tax matter involving a 1031 like-kind exchange issue. Case resolved in client’s favor. (2023)

Taxpayer assessed approximately $3.8 million over three years for back income taxes. Appealed assessment and proved that the revenue agent made assessments in error. Case settled for approximately $2,500.

IRS Audits & Audit Reconsideration

Client had an initial IRS audit balance of $300,000. Filed for audit reconsideration. Liability reduced to $0. (2022)

Client had an initial IRS audit balance of $104,013. Filed for audit reconsideration. Liability reduced to $4,132. (2021)

Client had an initial IRS audit assessment of $155,049. Filed for audit reconsideration. Liability reduced to $20,152. (2021)

Client was audited by the IRS and assessed $125,918. Filed for audit reconsideration. Initial assessment reversed in full; client received a refund of $71.43. (2021)

Client had an IRS liability of $391,094.73. Client had not filed returns for the years in question. Obtained the necessary records and filed the returns. Final liability: $1,192.80 including all penalties and interest. (2020)

Doctor was assessed for approximately $2.8 million in back taxes. Proved that assessments were made in error. Case settled for approximately $70,000.

Private arm of a public corporation was assessed for approximately $1.2 million in back taxes for various subsidiaries’ income tax, failure-to-file penalties, and related charges. Proved that assessments were made in error. Case settled for approximately $46,000.

State & Local Tax Audits

Client’s NYC Hotel Tax audit resulted in an assessment of $719,823.55. Negotiated final liability to $258,700.72 — a reduction of $461,122.83. (2024)

NYC transfer tax deficiency protest of $176,900.79. Assessment reduced to $0. (2024)

Nursing agency under IRS payroll tax audit with a balance of $1,000,000. Reviewed and analyzed the assessment. Balance reduced to $0. (2024)

Corporate income tax audit proposed tax on $1,500,000 in income. Audit resolved with additional tax of $29,000. (2024)

Client won Employee Retention Credit audit; 95% of the original credit claimed was distributed. (2024)

Employee Retention Credit refund of $374,000 secured for client. (2025)

Client was audited for a sales tax balance of $15,000,000. The state had assessed based on a lack of evidence of proper withholding. Provided an analysis and reconstruction of client’s books and records. Final assessment: $15,000. (2021)

Client’s sales tax balance reduced from $291,375 to $30,290 — a savings of $261,085. (2020)

Client’s audit assessment of $331,000 reduced to $0 through analysis and reconstruction of books and records. (2021)

Client was audited for NYC Commercial Rent Tax. The initial audit, handled by a real estate attorney, resulted in a $1,075,019 determination plus an additional audit for years outside the original audit period. Firm reviewed the tax returns and each of the 14 leases and proved that no single property exceeded the threshold for Commercial Rent Tax liability. At a subsequent conciliation conference — at which point the assessment with penalties and interest had reached $1,107,320 — the conciliator closed the case with a no-tax-owed determination. (2020)

Residency Audits

New York State residency tax assessment of $108,883.87. Full assessment abated through negotiation. (2025)

IRS Collections & Levies

Day trader was assessed for over $1 million in back taxes and accounts levied with all tax liabilities seized. Argued and proved correct liabilities. The total amount levied was refunded by the IRS.

Executive was assessed for over $457,000 in back income taxes and accounts levied with all tax liabilities seized. Argued and proved correct liabilities. The total amount levied was refunded by the IRS.

Penalty Abatements

IRS tax abatement of $1,381,000 negotiated on behalf of client. (2023)

$107,000 in IRS penalties abated after proving non-willfulness to the IRS. (2023)

$37,000 in IRS penalties removed through negotiation. (2022)

Large penalty abatement secured for client after negotiation in Tax Court. (2022)

Taxpayer was assessed $75,000 in penalties. After demonstrating reasonable cause for late filings, penalties were abated.

Taxpayer was assessed $55,000 in penalties. After demonstrating reasonable cause for late filings, penalties were abated.

Responsible Person Assessments

• Former partner of a partnership was assessed approximately $425,000 of trust fund recovery penalties arising from nonpayment of withholding taxes. Protested assessment and proved that partner was not responsible. The full assessment was vacated.
• Former partner of a partnership was assessed approximately $160,000 as a responsible person arising from nonpayment of sales taxes. Protested assessment and proved that partner was not responsible. The full assessment was vacated.
• Former treasurer of a corporation was assessed approximately $187,000 of trust fund recovery penalties arising from nonpayment of withholding taxes. Protested assessment and proved that treasurer was not responsible. The full assessment was vacated.
• Former owner of a New York corporation was assessed approximately $1 million as a responsible person arising from nonpayment of sales taxes. The full assessment was vacated.
• Former partner of a partnership was assessed approximately $25,000 as a responsible person arising from nonpayment of sales taxes. Protested assessment and proved that partner was not responsible. The full assessment was vacated.
• Former store manager was assessed approximately $140,000 as a responsible person arising from nonpayment of sales taxes. Protested assessment and proved that manager was not responsible. The full assessment was vacated.

Innocent Spouse Relief

Elderly widow discovered that there was an $80,000 lien filed against her. Executed innocent spouse relief. The assessment was vacated and the lien withdrawn.