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Case studies

Case Studies

A selection of outcomes obtained for clients before the IRS, state taxing authorities, and the U.S. Tax Court.

Resolved — Assessment removed

$413,000 in Ohio sales tax assessments removed for a wholesaler

The Ohio Department of Taxation issued $413,000 in estimated sales tax assessments against a wholesaler holding a vendor's license it never needed — the business made no retail sales subject to Ohio sales tax. We retroactively closed the license and had the assessments removed.

Assessed$413,000
Final liability$0
Removed$413,000
Assessments removed100%

What we did: Established that the business made only wholesale sales not subject to Ohio sales tax, retroactively closed the vendor's license with the Ohio Department of Taxation, and secured removal of the full estimated assessment.

Resolved — $0 tax owed

$306,000 proposed assessment reduced to $0

A title company issued a 1099-S on the sale of the client's personal residence, prompting a $306,000 CP2000. We responded and the IRS made no change to the return.

IRS proposed$306,000
Final tax$0
Saved$306,000
Proposed tax eliminated100%

What we did: Responded to the CP2000, established the gain on the sale of a personal residence, and obtained a no-change result with no additional tax due.

Resolved — Refund recovered

$210,000 IRS balance reversed into a refund

The client's amended return had gone unprocessed while collection advanced. We stopped collection, got the returns processed, and turned a $210,000 balance into a refund.

IRS balance$210,000
OutcomeRefund issued

What we did: Filed the client's past-due return, filed a Collection Due Process request to stop collection, and resolved the matter in IRS Appeals — converting the balance into a refund.

Resolved — Penalties fully abated

$200,000+ in IRS penalties fully abated

An Ohio farmer faced more than $200,000 in IRS penalties. We pursued penalty abatement and the IRS abated the penalties in full.

Penalties at stake$200,000+
AbatedIn full
Saved$200,000+
Penalties abated100%

What we did: Prepared and pursued a penalty abatement request for an Ohio farmer and secured full abatement of more than $200,000 in IRS penalties.

Resolved — Assessments removed

Estimated Ohio sales tax assessments eliminated for closed businesses

Businesses that shut down but never closed out their vendor's licenses kept accruing estimated sales tax assessments from the Ohio Department of Taxation. We retroactively closed the licenses to their final dates of business and had the assessments removed.

Assessments$20,000–$200,000
LicensesClosed retroactively
OutcomeAssessments removed

What we did: Documented each business's final date of operations, retroactively closed the vendor's licenses with the Ohio Department of Taxation, and secured removal of the estimated assessments issued after the businesses stopped operating.

Resolved — U.S. Tax Court

$40,300 deficiency eliminated in U.S. Tax Court

The IRS assessed a $40,300 deficiency arising from identity theft. We petitioned the U.S. Tax Court, and the case resolved with no deficiency for the year at issue.

IRS deficiency$40,300
Final result$0
Saved$40,300
Deficiency eliminated100%

What we did: Filed a Tax Court petition, established that the liability stemmed from identity theft, and secured a no-deficiency disposition.

Resolved — Refund recovered

$30,000+ frozen refund recovered and released

The client had elected a refund on their return, but the IRS applied it as a credit toward the next year's taxes. We got the IRS to reverse the credit and issue the refund.

Refund at stake$30,000+
OutcomeReleased

What we did: Established the client's refund election, challenged the IRS's credit-transfer coding, and secured reversal and issuance of the full refund.

Resolved — $0 tax owed

$22,000 proposed assessment reduced to $0

The IRS proposed more than $22,000 in additional tax based on an incorrect 1099-R. We contested the CP2000 and the IRS accepted the return as filed.

IRS proposed$22,000+
Final tax$0
Saved$22,000+
Proposed tax eliminated100%

What we did: Responded to the CP2000 notice, demonstrated the 1099-R was issued in error, and obtained a no-change determination.

Resolved — IRS approved

$22,600 in penalties removed

We secured penalty relief under the IRS abatement program and placed the client into a manageable installment agreement to resolve the remaining balance.

Penalties removed$22,600
BalanceInstallment agreement

What we did: Filed for penalty abatement and negotiated an installment agreement covering the remaining liability.

Resolved — Back in compliance

Six years of back returns filed — full compliance restored, with refunds recovered

We prepared and filed six years of delinquent federal and state returns, bringing a non-filer into full compliance and recovering refunds of over-withheld tax.

Tax years filed6
Federal & stateCompliant
Over-withheld taxRefunded

What we did: Reconstructed and filed six years of federal and state returns and secured refunds of over-withheld taxes.

Resolved — Levy released

Continuous wage levy released — 75% of each paycheck restored

The IRS was seizing 75% of the client's pay every period. We secured release of the continuous levy and placed the client into a partial pay installment agreement.

Wages seized75% / check
LevyReleased
AgreementPPIA

What we did: Engaged management within the local IRS office to release the levy, filed the client's unfiled returns, and proved above-standard medical expenses to secure a partial pay installment agreement.

Resolved — Collection stopped

Employment tax collection halted — Currently Not Collectible status secured

We brought the client into compliance and secured Currently Not Collectible status, stopping IRS collection on a substantial employment tax balance.

LiabilityEmployment tax
StatusCNC
CollectionHalted

What we did: Filed outstanding returns, requested a Collection Due Process hearing, and worked with the Revenue Officer during the appeal to provide financials and obtain CNC status.

Resolved — IRS approved

Favorable installment agreement secured after prior counsel failed

Where prior counsel could not get an agreement accepted, we petitioned the U.S. Tax Court, obtained remand to the Office of Appeals, and reworked the case to a favorable partial pay installment agreement.

Prior counselUnsuccessful
OutcomePPIA approved

What we did: Filed a Tax Court petition, moved to remand the case to the Office of Appeals, obtained approval, and reworked the matter in Appeals to secure a favorable partial pay installment agreement.

Results reflect the specific facts and circumstances of each matter. Prior results do not guarantee or predict a similar outcome in any future case.

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