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.

2012 David A. Solitare

 
 

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.

   

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