TAX LITIGATION: IRS Concedes 100% of Million Dollar Proposed Assessment Before Trial

This corporate taxpayer’s case had been pending in court for 1 year with another law firm before Wilson Tax Law Group took over. The taxpayer fired the previous attorney when the attorney advised the taxpayer to concede to the entire tax liability in exchange for the IRS’s waiver of a 20% penalty. There was only one problem: The taxpayer didn’t owe the taxes. Although the taxpayer’s former attorney was a “former IRS attorney,” he lacked the tried and battle-tested trial experience of the attorneys at Wilson Tax Law Group and the taxpayer hired Wilson Tax Law Group to take the IRS to task.

Wilson Tax Law Group looked at the underlying issues, obtained a last minute continuance of the trial date, went through all financial and tax records, and examined tax law. We put together supporting documents, created an entirely new legal position, did a thorough analysis, and showed why the government theory was wrong. This was a complicated tax analysis and involved an understanding of different types of complex accounting methods, tax law and federal litigation, since the client’s company had been legitimately using difference types of financial accounting methods for various purposes.

We worked to reconstruct the financial statements, worked as a team with the in-house and outside accountants for the company and were successful in obtaining a complete concession by the IRS of the proposed $1 million in pending tax liabilities.