RECENT MATTERS

Some of the matters Greg recently handled include:  


  • Designing and implementing a federal reportable transaction/material advisor disclosure program for a Wall Street financial institution


  • Securing a favorable private letter ruling request that permitted a company to make a late election (to elect out of the installment method) resulting in a tax savings of approximately $500,000


  • Negotiating an offer-in-compromise with the IRS reducing a company's tax liability from approximately $1.2 million to approximately $300,000


  • Representing a foreign-based company with U.S. operations in a collection due process hearing involving penalties relating to late-filed international information returns and securing a $100,000 penalty abatement (that is, an abatement of over 70 percent of the total assessed penalty), thereby permitting the financially strapped company to remain in business


  • Securing multiple favorable private letter ruling requests under Treas. Reg. Section 301.9100-3 for foreign entities in which the IRS permitted the entities to make late check-the-box elections


  • Securing approximately $3 million in penalty abatements between July 2014 and July 2015 for individual and business clients relating to various penalty assessments