Successfully resolved gift and estate controversy matters, including the following:
Tax Controversy Cases
Provide representation in various tax controversy cases in District Court and Tax Court, in addition to numerous audits that escalated through appeals but avoided trial.
Trade or Business
Represent clients in cases involving IRS examination of income tax related issues associated with trade or business activities.
Gift and Estate Tax Cases
Advised on private equity vertical slice gift tax and gift and estate tax cases related to profit/carried interests and other interests in investment properties and related valuation issues.
High Net Asset Valuations
Counsel clients in cases relating to the valuation of high net asset value assets with lower valuation as an on-going business, and coordinate strategy for disputes through court proceedings.
Chapter 14 IRC 2701
Manage cases involving partnership funding, transfer and administration with a focus on Chapter 14 IRC 2701 entities.
Grantor Trusts
Advise in cases relating to sales of assets to grantor trusts with and without self-canceling installment notes.
“Graegin” Loans
Represent clients in cases involving loans to estates structured as “Graegin” loans with successful defense through IRS examination.
Passive Activity Loss Cases
Counsel clients in passive activity loss cases under section 469 and hobby loss cases under section 183 of the Internal Revenue Code.
California and Federal Income Tax Disputes
Advocated for clients involved in adjusted basis determinations for domestic and foreign real estate involving reconstructed or missing substantiation in a number of California and federal income tax disputes.
State Estate Refund
Represented clients in a matter that lead to securing a state estate refund of nearly $2 million for a client after 9 years of tax controversy with the IRS.
Tax Penalty Matters
Acted in numerous penalty cases, including failure to pay penalties, failure to file penalties, accuracy-related penalties, fraud penalties and excise taxes, amongst others, by demonstrating reasonable cause.
Litigation
FBAR Litigation
Achieved case victory on willful Foreign Bank Account Report (FBAR) penalties before the United States District Court.
California Franchise Tax Board
Secured Section 1031 victories before the California Franchise Tax Board involving “swap and drops” and “drop and swaps.” Represent various clients in desk audits of source of income and residency matters.
Split-Dollar Life Insurance
Served as lead counsel on ongoing litigation involving split-dollar life insurance arrangements.
Low-Income Housing Development
Provided representation as lead counsel on ongoing litigation involving low-income housing development issues.