Practice Areas
A Redmond, WA, IRS‑Dispute Practice
Form 1120-F/Penalties for Failure to Withhold on FDAP/ECI
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Disputes over Assessed and Statutory Interest
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Disputes over Limitations Statutes, Including Mitigation, Equitable Tolling, Equitable Recoupment, Offset, and Informal Claims for Refund
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Disputes over Alleged Tax Shelters and Lack of Economic Substance
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Challenges to the Faulty Regulation under IRC s. 1061(c)(4)(A) Respecting the Taxation of Carried Interest Paid by Hedge Funds
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Disputes over the Valuation of Tangible and Intangible Property, including Goodwill
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Disputes over Alleged Prohibited Transactions
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Deductions for Worthless or Partially Worthless Debts
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Disputes over Charitable Contributions Made to Donor-Advised Funds
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Disputes over Proper Responses to IRS IDRs, Formal Document Requests, and Summonses (Issued During Audits)
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Responses to IRS CP-Series Forms — CP2000, CP162, etc. (Precursors to an Audit)
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Removal and Enforcement of IRS Liens and Levies
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Disputes/Controversies Involving the U.S. Constitution (Not Limited to Tax Issues)
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Challenges to Federal Rules and Regulations that Overreach (Not Limited to Tax Issues)
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Federal Tax-Return Filing Obligations of Visa and Green-Card Holders
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Foreign Bank Account/FBAR Non-Filings and Disputes
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Amendment of Tax Returns to Include Form 8938, Respecting Specified Foreign Financial Assets (FATCA)
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Amendment of Tax Returns to Include a Form 5471, Respecting Certain Interests in Certain Foreign Corporations
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Amendment of Tax Returns to Include a Form 3520, Respecting Receipt of Certain Foreign Gifts and Transactions with Foreign Trusts
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Disputes/Controversies with the U.S. Department of Justice
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Disputes/Controversies with the U.S. Department of the Treasury
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Disputes in Federal Courts, Including Appellate Courts
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State and Local Tax Disputes and Litigation in IL, DC, and WI
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Disputes with the Wisconsin Department of Natural Resources
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Corporate Transparency Act (Proposed Regulations Issued by FinCEN on 12/8/21)
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Cryptocurrency Reporting, Including on Amended Returns
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Appeals of Social Security/Medicare Benefit Adjustments Under IRMAA
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Suspicious Activity Reports (SAR)/Anti-Money Laundering (AML)
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