The Miscalculated Income

Success & Experience

Audit Representation

• (lifestyle): IRS Alleges Unreported Income
• Real Estate for Business Purpose
• Defense of a Private Foundation

Commercial / Corporate Representation

• Disallowed Deductions
• Commercial Litigation
• Corporate Representation: Back Payroll Taxes, Avoiding Payroll Tax Problems

Controversies and Litigation

• Commercial Litigation
• Corporate Representation: Back Payroll Taxes, Avoiding Payroll Tax Problems

Criminal Representation

• Avoid Criminal Prosecution
• Avoiding Criminal Prosecution
• Criminal Representation: Bribery, Racketeering, Wire Fraud
• Federal Criminal Representation

Federal and State Tax

• Levy Release
• Examples of recent legal opinions rendered
• Examples of recent Private Letter Rulings Obtained
• Examples of recent Closing Agreements

IRS Audit

• Tax Return Preparer
• Favorable Settlement
• Incorrect Reporting of Stock Options
• Disallowed Mortgage Interest Deduction
• Reduction of Tax Liability
• Timing is Everything

Municipality Representation

• Municipality Representation: Deferred Compensation Plan Compliance

Offer In Compromise

• Federal Income Tax
• State of California Income Tax
• Offer in Compromise
• Client keeps business doors open while settling tax debt

Personal

• Disallowed Mortgage Deduction
• The Miscalculated Income
• The Unwelcome Auditor
• The Flood
• The Innocent Spouse

Real Estate Professionals

• Significant Losses in the Trade
• A Real Estate Professional & a Small Business Owner

Refund Representation

• Disallowed Numerous Losses
• Numerous Foundations in the Cayman Islands

Tax Court

• Disallowance of Expenses
• Losses in a Ponzi Scheme
• Significant Losses in a Ponzi Scheme
• Tax Shelter
• The Tax Bill
• The Audit Gone Wrong
• Business expenses, business use of aircraft and/or flights
• The Unreasonable Auditor
• The Real Estate Professional

 

After receiving an audit notice, our clients in this case discovered that they inadvertently committed an error in calculating the income they received and therefore under-reported a hundred thousand dollars on the income tax return being audited. Given the amount of taxes involved, our clients were facing serious risk of a criminal referral by the auditor or the imposition of substantial civil fraud penalties in addition to the tax liability and interest the clients knew they would owe.

The attorneys of Moskowitz LLP successfully assisted our clients in complying with the voluntary disclosure procedure to the Internal Revenue Service with regards to the error to minimize their criminal exposure after the audit had already been initiated. The attorneys of Moskowitz LLP were then able to convince the auditor not to make a criminal referral or even assess civil fraud penalties. Moskowitz LLP then worked out payment arrangements with the Internal Revenue Service so that our clients could pay back the additional tax liability within a reasonable time and without any enforced collection activity of any kind.

If you have received a notice of an income tax audit by the Internal Revenue Service or state tax agency, it may be imperative for you to consult with an experienced tax attorney immediately. Any information you provide to an auditor or examiner can and is often used to attempt to assess additional taxes, penalties, and interest. Do not ignore the problem. The failure to respond to an audit notice can lead to a summary assessment of substantial taxes, penalties, interest followed by the seizure of income and assets including wages, bank accounts, automobiles, and real property.

The results portrayed in the cases mentioned above were dependent on the facts of that particular case, and the results may differ if based on different facts. The case study and/or success stories shared herein are for informational purposes only. It is not intended to and does not constitute legal advice. For more information please call 1∙888∙TAX∙DEAL or (415) 394-7200 or complete our contact form.