The information provided here is for informational
purposes only. It is not,
nor is it intended to be, legal advice.
You should consult an attorney for
individual advice regarding your own situation.
Tax attorneys in the Law Offices of David
A. Solitare leverage sophisticated and innovative approaches in
a variety of tax issues. The tax practice covers the full spectrum
of taxation for all types of entities, including corporations, limited
liability companies, partnerships, associations, estates and individuals.
We develop strategies for future tax savings,
including tax planning on business, personal and investment transactions
with tax implications. We provide tax guidance to clients in all
phases of a transaction. We work closely with your certified public
accountant, financial adviser, or relevant taxing authority to obtain
the best result possible.
In
addition to tax planning, we provide counsel in the following
areas:
Compliance
Review
Income
Tax
Estate
Tax
Gift
Tax
Property
Tax
Sales
Tax
Audit/Appeal/Collection
Client
Representation on Audit
Appeal
of Disagreed Cases
Administrative
- Within Tax Agency
Judicial
- Through the Courts
Settlement
of Collection Matters
Installment
Payment Plans
Offers
in Compromise
Innocent
Spouse Claims
Our tax lawyers have significant expertise
representing clients with disputes before the taxing authorities,
including:
Internal
Revenue Service
Franchise
Tax Board
State
Board of Equalization
County
Assessor
Municipalities
We have been successful in utilizing offers
in compromise and other approaches to significantly reduce tax liability.
Furthermore, in situations where litigation is necessary, we represent
clients before the United States Tax Court with excellent results.
Situation: A male recording artist in his twenties
had issues on 7 tax returns over a 10 year period. He had neglected
to file some returns, and others he had filed, but not paid. Ten
years ago, he filed a return showing a balance due of $40,000, which
he never paid. He came to us owing an additional $34,000 in penalties
from that single year; his combined taxes and penalties came to
$83,000.
Solution: Present an offer in compromise to
the IRS. With the client's assets totaling about $5,000 and his
living expenses exceeding his income, we were successful in obtaining
a reduction in his liability, allowing him to pay what he could
afford and start with a clean slate. This is an exceptional case
- his specific facts permitted us to achieve such a dramatic result.
Benefit: Taxes owed reduced from $83,000 to
$6,000.
Situation:
Client's property value was reassessed from $103,775 to $450,000.
The reassessment was triggered by some errors committed by a less
experienced attorney in establishing
his family limited partnership. The partnership was structured with
the client and his spouse having 90% ownership interest and each
of his two children having 5%. The property, however, was owned
100% by the client and his spouse. He transferred it to the partnership,
which changed the ownership interest of the property, thereby triggering
a reassessment.
Solution: We showed that the client treated
the property as though it was 100% owned by him and his spouse over
the two year period in question, based on tax returns and maintenance
activities.
Benefit: Assessment reversed, saving $6,200
in property tax per year.