I limit my practice to tax planning, preparation and controversy. Specialization is the only way I can provide the level of expertise my clients deserve.
I received my Master of Taxation from Florida Atlantic University. The Mtax degree requires thirty hours of graduate level tax courses. The program is a fundamental tax research, compliance and problem solving learning experience! The emphasis is on tax law, starting with the Code, Regulations and statutory case law in the most current possible means.
Thirty-two students started the program; seven graduated along with me. I graduated with a 3.889 GPR.
Tax Return Preparation
I prepare tax returns for all types of entities, individual, S Corporation, LLC, or C Corporation.
Ideally, the preparation of the return should be the last step in completing the overall tax plan, but I file a lot of tax returns where that is my
first chance to minimize taxes, and opportunities exist at that point as well.
Fees are usually quoted before any work is begun. Payment is normally expected when the returns are completed.
I encourage electronic filing whenever possible. It is faster, more accurate and has better documentation for filing and compliance purposes, especially for assessment and Statute of Limitation issues.
Tax Return Review
I will review any return at no charge, whether taxpayer prepared or prepared by another professional.
I have saved many thousands of dollars for taxpayers, usually not because of mistakes of other preparers, but due to new and original thinking. You will be surprised at the unique and clever approaches that can be used to solve tax problems.
In one instance, I was asked to review a return because the taxpayers could not pay the tax. After I was through not only did the taxpayer not
owe any tax, they received nearly $60,000 in refunds. Given the money and importance of tax filings, an independent review is frequently the best insurance someone can buy.
IRS Examinations & Appeals
The best solutions to most tax examinations occur at the agent level. If it is possible to resolve a case at that level, usually that’s the
least expensive, both in terms of tax to be paid and representation fees. If possible, I love to have an opportunity to be involved in an
examination before everyone has “drawn a line in the sand” or at least before the final report has been written. No one likes to be shown up,
and agents are people too. If it is possible to present documentation or authority that the agent can accept, that is the place to do it.
Unfortunately, I rarely get involved with a practitioner referred case until late in the process. That doesn’t mean nothing can be done. To the contrary, sometimes the best approach is a new one. That’s why the IRS uses an appeals officer who has no previous contact with the case. By entering the case after the battle lines have been drawn, I have the distinct advantage of not being limited to a previous position. My approach is fresh, and sometimes a different approach yields results. I am very pragmatic in IRS examinations; I will concede minor issues if I think the major issues can be won as a result.
As a practitioner, what happens when you have gone as far as you can with the Examination Division? Appeals? Tax Court? Capitulation? I can provide valuable assistance in evaluating possible courses of action, considering the possible costs and contingencies of each avenue.
Entity Selection & Maintenance
The selection of the proper entity is one of the most important and least understood formation issues that a taxpayer could face today. The second most important issue is entity retention and maintenance. Just because an LLC was the right choice at one time does not make it the right choice for all time. Do you need to change your tax structure? What’s the cheapest, most effective manner?
If I could wave my magic wand, this would be the one issue I would want every business account to review on a regular basis.
I have saved clients many thousands of dollars in tax by switching entities, or changing the characteristics of the existing entity. Did you know an LLC can elect to be taxed as an S Corporation, without changing legal status? Is there ever a reason to keep or form a traditional C Corporation any more? What are the consequences of being a single member LLC? What happens if more or fewer members remain in an LLC?
Tax Opinions & Research
My training and education were focused on learning one important task: providing a specific answer to a complicated question. Successful Tax research has one central theme – what is, and what can be. To be successful as a tax Specialist, I have to be able to quickly gather an understanding of the particular facts and circumstances of the case, research the applicable Internal Revenue Code and authority, form an opinion as to the tax consequences of the action or proposed course of events, then communicate that to the client and advisors in a clear and understandable manner.
It is nor enough to answer a question. What the client really wants is a solution to a problem. Of all the things I’ve been called in my life, clever is one I’m proud of. You have to be clever, creative and inventive, not of facts and law, but of the application of alternative applications of competing theories. What course of action, within the applicable Code and supporting case law, will produce the results the client is looking for?
Advanced Corporate Transactions
• Mergers, Reorganizations, Recapitalization
• Split offs, spin offs and split ups
• Surviving Tax Attributes in reorganizations
• Consolidated and affiliated returns
• Like Kind Exchanges
• Form 3115 Fixes
• Estates & Trusts