Our attorneys evaluate every case to ensure that all possible legal theories are advanced and well-crafted, and that the facts supporting the position are thoroughly developed to increase the chances of a favorable resolution at the audit level. We often work closely with the clients’ other professionals and tax preparer, and can ensure that all possible privileges are maintained. As our attorneys also defend clients in criminal tax investigations, we are well-positioned to help clients navigate the IRS audit process when fraud is or could be suspected and a referral to the criminal division of the IRS is possible.

Case Studies

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.

Millennium Tower
719 Second Ave., Suite 711
Seattle, WA 98104