Practice Areas
My practice is limited to taxation. Specific areas of expertise include:
- Experienced tax penalty relief attorney. I have extensive experience in successfully obtaining waiver of IRS penalties suggested or abatement of assessed penalties, including:
- Domestic related penalties for late filing, late [payment, substantial understatements.
- Foreign reporting related penalties for failure to timely file IRS Forms 5471 (interest in foreign corporation), 5472, (foreign person’s interest in U.S. corporation), 3520 (interest in foreign trust or receipt of gift from foreign person), 8938 (interest in specified foreign financial assets), 8865 (interest in foreign partnership), FinCEN Form 114 (FBAR) and other foreign related forms.
- Preparation of reasonable cause statements for submission with delinquent or amended returns for penalty waiver or abatement requests.
- Coming into tax compliance via the IRS Streamlined Filing Compliance Procedures.
- IRS Voluntary Disclosures – IRS amnesty program for those who have committed tax crimes.
- Representation in IRS audits including large case international audits.
- Appeal of penalty abatement denials or IRS adjustments.
- Consultation regarding divorce tax matters.
- Preparation of high income complex personal income tax returns or amended returns.
- General tax advice consultations.