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Persuasiveness Prevails

Arthur Pearson and Karen Neville successfully persuaded the IRS to abate a $480,000 late payment penalty assessed against a fashion designer, manufacturer and retailer of women's clothing. The required estimated tax payments were late as a result of miscommunications between the taxpayer and the accountant. This abatement resulted in an avoidance of litigation between the parties.

Arthur Pearson and Jason Galek successfully persuaded the IRS to abate $140,000 in penalties assessed against an estate whose executors failed to timely file the estate tax return and to pay the necessary estate taxes as a result of being unfamiliar with legal and tax issues associated with the managing an estate. The IRS imposed $107,127.67 in a failure to file penalty and $57,134.76 in a failure to pay penalty. Through abatement efforts, the IRS agreed to waive the failure to file penalty in total, and to reduce the failure to pay penalty to $32,858.49.

Arthur Pearson and Jason Galek successfully persuaded the IRS to abate a substantial accuracy related penalty in the amount of $238,000 arguing that a written tax return constitutes advice by a tax professional for purposes of the reasonable cause abatement provision under IRC § 6662.

Arthur Pearson and Janet Everson successfully persuaded the IRS to abate an $83,000 failure to pay penalty based on an argument that the taxpayer reasonably relied upon the advice of a tax professional who had miscalculated the due date for the return.

 

 

 

 

 

 

 

 


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