Results

We take pride in each favorable result we achieve for our clients – from the abatement of minor penalties to the successful reversal of a multi-million dollar assessments proposed by the IRS following an audit.  Our client success stories include:

• Assisted a group of related for-profit corporations and tax-exempt organization managers in resolving over $6 million of proposed excess benefit transaction excise taxes at IRS Appeals for less than $50,000.
• Assisted a private foundation and its managers in settling over $100,000 of proposed self-dealing excise taxes for pennies on the dollar during an IRS examination (audit).
• Assisted private foundations in proactively obtaining closing agreements from the IRS favorably resolving various tax issues including the non-filing of Forms 990-PF, the failure to pay the section 4940 net investment income tax, the failure to exercise expenditure responsibility over grants to domestic and international organizations, and the failure to make sufficient qualifying distributions. In these cases, we were able to negotiate a substantial reduction or elimination of related excise and penalty tax liabilities for our clients.
• Conducted a highly publicized internal investigation of a private university that examined allegations in the media and by current and former employees regarding conduct of the university’s former president, and made recommendations for self-corrective actions to address potential areas of noncompliance with federal income tax laws.
• Assisted a family foundation and related charitable organizations in obtaining a series of favorable technical advicememoranda from the IRS resolving numerous issues raised during an IRS audit of the organization, including the supporting-organization status of one of the organizations and significant potential liabilities for self-dealing excise taxes, excess business holdings excise taxes, and the unrelated business income tax.
• Conducted a compliance review and risk assessment for an international nonprofit organization and identified proactive solutions for addressing potential noncompliance with federal income and employment tax laws.
• Assisted various tax-exempt organizations in obtaining favorable IRS private letter rulings that, among other things, ruled that certain activities would not jeopardize the organization’s tax-exempt status; that certain property sales were eligible for the section 512(b)(5) exception from the unrelated business income tax; and that certain activities and expenditures would not affect the organization’s public charity classification.
• Assisted a worldwide ministry in obtaining a “no change” letter following an IRS audit challenging its church status and proposing revocation of its tax-exempt status.
• Assisted numerous clients in establishing the reasonable cause necessary to obtain abatement (waiver) of penalties for late or non-filing of Forms 990 or 990-PF, Forms 1120-POL, and Forms W-2.