Case #1: $1,200,000 IRS Liability Settled for Approximately $300,000 |
| |
Situation
The taxpayer is a physician who had accumulated liabilities with the IRS and other taxing authorities over a period of about fifteen (15) years. Our office reviewed the issues outstanding, made some strategic planning decisions, and ultimately filed bankruptcy under Chapter 7 of the U.S. Bankruptcy Code.
Our office, on behalf of the taxpayer, brought suit against the Internal Revenue Service in bankruptcy seeking to discharge most of the tax liabilities at issue. |
| |
Process/Resolution
The taxpayer received a discharge of his debts through the Chapter 7 filing. We ultimately negotiated a settlement with the Internal Revenue Service wherein approximately $900,000 of the IRS liability was discharged and the remaining sum due is being paid interest free through a payment plan.
On behalf of the taxpayer we were also able to amend several years' of the tax returns at issue and bring to the client an additional $100,000 in tax savings. |
|
Case #2: $125,000 Tax Bill Settled for $10,000 |
| |
Situation
The taxpayer was a small business owner. Her income and expense records for several tax years were destroyed. Shortly thereafter, she received notice that the IRS planned to audit her records for the same years. The taxpayer had no records to substantiate her business expenses and as a result, all expenses were disallowed. She received a bill from the IRS in excess of $125,000. Prior to arriving at our office, the taxpayer met with another tax professional who told her she had no choice but to pay the bill in full.
|
| |
Process/Resolution
Our office met with the taxpayer to discuss her options. Based on her income, assets & liabilities, our office determined that she was a good candidate for the IRS’ Offer-in-Compromise Program. After approximately 7 months of careful planning and negotiations, our office was able to settle the tax debt for $10,000.
The OIC program was developed by the IRS in order to assist taxpayers who will not be able to pay the full amount of their tax liabilities within the requisite time frame. Both Individuals and businesses may qualify for this program. Our office will review monthly income and expenses as well as the value of your equity in assets to determine if you are a good candidate for the program. Not all taxpayers qualify, and beware of tax resolution services that make promises to the contrary! But for the select group of taxpayers who do qualify, the savings can be substantial. |
|
Case #3: $475,000 Tax Bill Settled for $70,000 |
| |
Situation
Taxpayer is a medium size business that had not filed or paid payroll taxes for three (3) or four (4) years. Its total IRS liability was approximately $475,000, with a substantial sum of interest and penalties accumulating daily.
The taxpayer was concerned about staying in business, resolving its problems with the Internal Revenue Service, and avoiding criminal prosecution for its actions. |
| |
Process/Resolution
We immediately acted to get the taxpayer in compliance with its payroll obligations. All past due payroll tax returns were filed and the taxpayer began to make payroll deposits on its current payroll obligations. We then reviewed which options best suited the client. The options included bankruptcy reorganization, liquidating the business, paying the liability in full, or filing an offer in compromise.
Once we were able to keep the client “current” for six (6) months, and based on its income, assets & liabilities, we determined that the company was a good candidate for the IRS’ Offer-in-Compromise Program. After approximately twelve (12) months of careful planning and negotiations, our office was able to settle the tax debt for $70,000.
|
|
Case #4: Business Owner Under Criminal Investigation Avoids Prosecution |
| |
Situation
Taxpayer-Business Owner had failed to file payroll tax returns or pay any payroll taxes for approximately an eight (8) year period. Robert J. Fedor, Esq., LLC was consulted and developed a strategy to work with IRS criminal investigation and also work toward bringing the taxpayer into compliance.
All of the outstanding payroll tax returns were filed immediately. We retained a payroll service company to begin withholding and impounding deposits. |
| |
Process/Resolution
After months of negotiations, we were able to convince the Internal Revenue Service Criminal Investigation Division that this particular taxpayer would not make a good criminal prosecution candidate.
The business was ultimately sold prior to any tax liabilities being assessed against the corporation. To this day (2008), the taxpayer himself does not owe the IRS anything. The taxpayer now collects a regular check from the sale of the business and remains in possession of his retirement income. |
|
Case #5: Physician Business Owner Ends 10 Year IRS Battle |
| |
Situation
In the early 1990's, a physician/business owner had deducted several hundred thousand dollars on his tax return related to farming and other business expenses. The IRS conducted and audit and determined that the taxpayer owed several hundred thousand dollars in additional tax, penalties and interest.
The taxpayer sought legal representation and tried the case before the United States Tax Court. After spending tens of thousands of dollars in legal fees, the Tax Court held in favor of the IRS. |
| |
Process/Resolution
A year later he sought out Robert J. Fedor, Esq., LLC as possible counsel. We analyzed the case and determined that a chapter 11 plan of reorganization (bankruptcy filing) could eliminate ninety percent (90%) of the tax liabilities and the remianing ten percent (10%) could be paid through a plan over a five (5) year period.
The case was a success because our office took the time to analyze the case properly, examine the options available to the client and, ultimately, help the client decide what the best course of action would be. |
|
