The Internal Revenue Code includes more than 250 penalties. We have helped clients avoid penalties, defended against penalties that were assessed, successfully asked to have penalties abated, and litigated them. This includes Trust Fund Recovery penalty cases involving IRS investigations, appeals from Collection Division recommendations to assess the TFRP penalty, and refund litigation to determine that our client is not liable.
We have defended many clients who allegedly promoted abusive tax shelters and who face extreme penalties under IRC §§ 6700, 6702 and 6707. We have done so on behalf of alleged “promoters” before the IRS, the California Franchise Tax Board, and the New York State Department of Taxation. This is a difficult and expensive process for any client to endure, but our experience is unique.
Whether it is penalties resulting from unpaid employment taxes, failure to file or pay, negligence or fraud, we are glad to consult with you and consider trying to help you avoid them. This may be done administratively, in IRS Appeals, or through the courts. We have very unique experience in this area.