Success Stories

The Miscalculated Income

After receiving an audit notice, our clients in this case discovered that they inadvertently committed an error in calculating the income they received and therefore under-reported a hundred thousand dollars on the income tax return being audited. Given the amount of of taxes involved, our clients were facing serious risk of a criminal referral by the auditor or the imposition of substantial civil fraud penalties in addition to the tax liability and interest the clients knew they would owe.

The attorneys of the firm of Stephen Moskowitz, LLP successfully assisted our clients in complying with the voluntary disclosure procedure to the Internal Revenue Service with regards to the error to minimize their criminal exposure after the audit had already been initiated. The attorneys of the firm of Stephen Moskowitz, LLP were then able to convince the auditor not to make a criminal referral or even assess civil fraud penalties. The attorneys of Stephen Moskowitz, LLP then worked out payment arrangements with the Internal Revenue Service so that our clients could pay back the additional tax liability within a reasonable time and without any enforced collection activity of any kind.

If you have received a notice of an income tax audit by the Internal Revenue Service or state tax agency, it may be imperative for you to consult with an experienced tax attorney immediately. Any information you provide to an auditor or examiner can and is often used to attempt to assess additional taxes, penalties, and interest. Do not ignore the problem. The failure to respond to an audit notice can lead to a summary assessment of substantial taxes, penalties, interest followed by the seizure of income and assets including wages, bank accounts, automobiles, and real property.

The Unwelcome Auditor

Our clients in this case were facing an extremely aggressive Internal Revenue Service auditor who believed that income was not reported on the income tax return being audited. At one point, the auditor issued a series of summonses demanding that our clients allow him to personally interview them in their home. The auditor wanted to use these summonses not only to interview our clients but also search their home.

The attorneys at Stephen Moskowitz, LLP were able to finally convince the Internal Revenue Service that it was probably illegal for them to try to search a home of a taxpayer in this manner. However, this was not an easy process. In the course of this dispute, the Internal Revenue Service issued summons after summons and even threatened to file a action in Federal District Court to allow them to enter the residence of our client.

The Flood

Our clients facing an audit from the Internal Revenue Service in this case had always kept meticulous records of their significant business expenses. Unfortunately, all of these records were lost due to a flood which had taken place many months before the clients received notice of the audit by the Internal Revenue Service. Prior to retaining the attorneys of Stephen Moskowitz, LLP, the auditor handling the audit indicated that he would disallow virtually all of the business expenses resulting in a substantial assessment of tax, penalties, and interest.

The attorneys of Stephen Moskowitz, LLP were able to assist our clients in reconstructing expense records of business expenses through alternative means for the majority of the expenses which were originally disallowed by the auditor and convince the auditor to allow most of the expenses that he disallowed.

The Innocent Spouse

The attorneys of the Stephen Moskowitz, LLP have successfully represented numerous clients who have been assessed enormous income tax, penalties, and interest as a result of the actions or inactions of their spouses.

An example of just such a matter in which the attorneys of Stephen Moskowitz, LLP have handled is described below.

The state of Washington assessed a business owner approximately $180,000 ofstate sales tax liability. Since the business owner failed to satisfy the assessed sales tax liability, the state of Washington proceeded to collect the outstanding sales tax liability from his former spouse by issuing a state tax warrant against her.

The attorneys of Stephen Moskowitz, LLP timely requested an administrative hearing with the state of Washington Department of Revenue. Through extensive negotiations, the attorneys of Stephen Moskowitz, LLP convinced the state of Washington Department of Revenue to remove the tax warrant issued against the client. This resulted in a savings of approximately $180,000 of state tax liability.

We want to represent you to defend against the assessment of additional tax liability as the result of an audit or how to minimize your risk of criminal liability, the attorneys at Stephen Moskowitz, LLP want to provide you with strategies to lawfully minimize potential civil and criminal liabilities.

For a prompt evaluation of your case, please call us to schedule a confidential appointment.