Tax Planning & Controversy

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
  • Estate and gift taxes
  • State and federal income taxes
  • Employment taxes
  • Trust income taxes

We work in a fully integrated manner with our clients’ CPAs and financial advisors.

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;
  • 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”).