IRS Audits/Civil Tax Controversies

No Change Determination In IRS Audit Of Miniature Horse Business:

We were hired to represent the owner of a miniature horse business during an IRS audit. The IRS took the position that the operation was a hobby rather than a business and that a large refund, claimed by the taxpayer, based on losses during the year at issue, should be denied.

We executed a comprehensive strategy to educate the IRS revenue agent regarding horse businesses generally and the client's business specifically.

Through diligent preparation and skillful presentation we were able to persuade the IRS that the client's miniature horse business was, indeed, a business and not a hobby. The IRS issued a no change determination and the client received the full refund.

No Change Determination In Audit Of Business Owner's Tax Return:

We were hired to represent husband and wife entrepreneurs, with business holdings in the fishing and food service industries, in the audit of their income tax return. We worked diligently on the case and obtained a no change determination.

No Change Determination In Audit Of Rancher's Tax Return:

We were hired to represent the owners of a ranch business during an IRS audit. The IRS took the position that the operation was not a business and that losses for the year in question should be disallowed. We took steps to educate the revenue agent regarding ranch businesses generally and the client's business specifically. Through skillful presentation and negotiation, we persuaded the revenue agent that the client's operation was a business, and the losses at issue were allowed.

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