May 2014

Our clients, small business convenience store owners with 2 locations, initially handled an IRS audit on their own. The IRS’ final audit report reflected a total balance due of $129,822. Since the taxpayers did not agree with the IRS’ audit findings, they hired our firm to represent them in US Tax Court. Our representation resulted in a stipulated decision, without the need for trial, in which the IRS agreed to reduce the assessment from $129,822 to only $10,765 — a savings of over 90% from the final audit report.Successfully brought a complaint against the IRS within the US bankruptcy court in which the IRS agreed to discharge over $900,000 in taxes from tax year 1996. Our client initially filed bankruptcy on his own but after the bankruptcy concluded the IRS continued to seek to collect over $900,000 from our client. We argued that since our client reached a stipulated US Tax Court decision for tax year 1996, it qualified as a tax return-equivalent document and was therefore dischargeable in bankruptcy. The IRS ultimately agreed with our position. As a result the $900,000 liability for 1996 has been eliminated and the IRS is now prohibited from collecting.

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100 Bush St., Suite 501
San Francisco, CA 94104
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2880 Zanker Rd., Suite 203
San Jose, CA 95134
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