Tax Planning & Controversy for Businesses

The attorneys at Frank Leffingwell & Associates, PC are experienced in helping clients anticipate and plan for future tax issues. We provide experience-based advice on planning, reporting, document retention, and other pre-controversy matters. Additionally, we represent clients during all administrative and investigative phases of civil tax investigations, examinations, and IRS lawsuits.

We represent clients in a wide array of diverse tax issues including:

  • Civil investigations and examinations
  • State and federal income taxes for businesses
  • Employment taxes
  • Payroll (trust fund liability) taxes
  • Texas franchise (margins) tax

We work in a fully integrated manner with our clients’ in-house counsel, tax directors, CFOs, and controllers.

Representative Transactions:

  • Negotiated with the IRS on behalf of a client with regard to past due payroll tax liabilities, resulting in tax savings for client of approximately $300,000.  The savings for the client were approximately 75% of the amounts the IRS initially alleged were owed.  The remaining tax liability was placed on a scheduled payment plan, allowing the client to avoid crippling the client’s newly started business.
  • Negotiated with the IRS on behalf of a client for the abatement of penalties for failure to pay and failure to file for two tax years, resulting in aggregate savings for the client in excess of $120,000.00;
  • Advised on and completed the restructure of a prominent newspaper business, resulting in Texas Franchise Tax savings in excess of $30,000 annually;
  • Structured and completed a complete overhaul of a prominent software company’s stock incentive plan to bring the plan into compliance with Code Sections 422 and 409A in order to avoid significant tax liabilities and penalties for the company and option holders;
  • Provided interstate and international tax advice regarding a complex investment partnership intended to take on investment in excess of $4,000,000, and completed the formation and investment of the partnership, including the formation of over twenty subsidiary entities of the partnership;
  • Successfully negotiated a favorable payment plan with the Internal Revenue Service on behalf of a client facing levies, tax liens, and foreclosures with respect to past due payroll taxes; and
  • Successfully represented an owner of a partnership in an audit by the Internal Revenue Service brought under the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”).