IRS AUDITS

Represented an executive in a gift tax audit relating to participation in an alleged tax shelter using grantor retained annuity trusts to gift over $40 million to his children and successfully defended the IRS’s challenge to the validity of the GRATs.

Represented a large vessel/yacht manufacturer in an audit involving a challenge to its inventory accounting, including a $2 million write down of scrapped and obsolete items and a $6 million deduction related to a cancelled contract. The audit resulted in no change; the IRS accepted the tax returns as filed.

Successfully secured the withdrawal of IRS summonses issued in response to a Russian Tax Treaty request for information from Russian expatriate.

Obtained a favorable resolution involving the IRS’s challenge that $6 million of a larger asset sale was a three party § 1031 exchange qualifying for deferral of gain.

Represented client in an IRS challenge to validity of client’s deduction for substantial deposit into capital construction fund; IRS conceded the issue on audit.

Assisted two taxpayers in claiming over $1.6 million in theft losses from fraudulent investment schemes and successfully defended the losses in an IRS audit, resulting in refunds of over $250,000 for the clients.

Represented a bankruptcy trustee in an audit of bankruptcy estate/taxpayers’ $2 million net operating loss deduction on real estate transactions; the IRS accepted the loss in its entirety.