US Tax Court

I have been admitted to practice before the US Tax Court. This is the highest designation of tax expertise that can be obtained by an attorney or
non-attorney. Fewer than 500 non-attorneys in the US are members of the Tax Court Bar.

So, what’s in it for you?
Negotiating power. 95% of all cases are settled before Tax Court. The IRS has litigation costs and the potential to lose, and they weigh that exposure on every case. If they know you can (and will) go to Tax Court, and it is not an idle threat, negotiations are much more serious. At
each and every level of the Appeals process, and even after filing a Tax Court petition, having the credentials that permit that case to go forward is a strong bargaining position.

What Else?
2nd opinions. I routinely give second opinions to other practitioners, and provide expert advice in tax cases. Is this a case to press? What
chance of a happy resolution exists, and what are your potential exposures? What are your strongest points? What are your weaknesses?

Business Valuations

A Business Valuation can be very valuable in a number of circumstances, and I am qualified to perform Certified valuations that comply with
IRS and the various Courts’ requirements. Common circumstances requiring a business valuation:

  • Divorce and marital settlements
  • Shareholder disputes
  • Income, Estate and Gift tax
  • Stepped up basis at transfers
  • Family Limited Partnerships
  • Damages in Lawsuits

Reliance Tax Opinions

A “Reliance Tax Opinion” is just what it sounds like – Tax advice that you can count on.

Tired of every letter or email having “Do not rely on this advice” disclaimers? Why  would you ask a question if you can not rely on the advice?

The Service has a whole host of penalties and sanctions against practitioners that provide tax advice that does not have a proper foundation of
legal reasoning and support, and does not meet their standards of preparation. My Tax Opinion Policy, meets or exceeds the Service’s requirements.

When I provide a “Reliance Tax Opinion” you can rely on it.