Client A had been involved in a longstanding and disputed IRS income tax audit which ultimately resulted in the referral of the taxpayer to the Criminal Investigation Division of the IRS. We were successful at convincing CID that the taxpayer had committed no crime and was entitled to a tax refund in at least one year in issue.
Client B had substantially underreported their taxable income on their U.S. income tax return, Form 1040, for many, many years. The IRS Criminal Investigation Division, and other federal agencies, began an investigation of the taxpayer for alleged unrelated criminal activity which never took place. However, during the course of the investigation, substantial amounts of unreported taxable income were discovered and, as a result, all other investigating federal agencies closed out their investigation of the taxpayer, but for the IRS Criminal Investigation Division. Although this particular taxpayer was facing a substantial period of incarceration, with the assistance of Stuart B. Ratner, P.C., the taxpayer received a nominal sentence of community service.
Stuart B. Ratner, P.C. represented a self-employed individual who neglected to file tax returns at any time during their lifetime. This particular taxpayer’s non-filing status was detected by the IRS Criminal Investigation Division due to CID’s ongoing criminal investigation of a business associate. With our assistance, the taxpayer pled guilty and received a sentence of home confinement.
Stuart B. Ratner, P.C. represented a self-employed taxpayer who had never filed a single tax return. In this particular case, the IRS used a net worth methodology to determine the increase in the taxpayer’s net worth from year to year, claiming that such increase must be from taxable income. Based upon our analysis, we demonstrated that the increase in net worth was as a result of borrowed funds.
Stuart B. Ratner, P.C. represented a tax preparer who allegedly understated his taxable income on his own personal U.S. individual income tax return. After an extensive investigation by the IRS Audit Division and a subsequent and extensive investigation by the IRS Criminal Investigation Division, we successfully convinced the U.S. Department of Justice to drop prosecution. The matter was returned to the IRS Audit Division which promptly assessed the taxpayer with very substantial additional income tax liabilities and a 75% civil fraud penalty. The matter was ultimately resolved by way of an offer in compromise for a nominal amount.
Stuart B. Ratner, P.C. represented a taxpayer who had no understanding of the U.S. tax laws or her tax filing obligations. Although this taxpayer did file income taxes on an annual basis, she fell victim to a third party preparer fraud scheme. Specifically, this third party “preparer” apparently had a friend at a major bank who could file false original issue discount returns, claiming that the taxpayer received substantial amounts of original issue discount income, substantially all of which was paid to the IRS as withholding tax. This particular fraudulent tax preparer prepared the taxpayer’s return in a manner which substantially overstated the taxpayer’s income and tax withholding by including the false original issue discount income and by including the very substantially overstated federal withholding tax. As a result, even though the taxpayer’s income was overstated, she received a very substantial refund of more than $300,000. The fraudulent preparer then demanded compensation from the taxpayer in the amount of 15% of the refund received and then stayed in contact with the taxpayer, advising her as to how to defend against the prompt IRS inquiry regarding the false refund. As a result of our efforts, prosecution was dropped by the local U.S. Attorney’s office after prosecution was initially approved by the U.S. Department of Justice. Further, amended tax returns were filed, yielding the taxpayer a small refund based upon legitimate errors in the prior year filings.
Stuart B. Ratner, P.C. represented a taxpayer who allegedly deducted substantial personal expenses on his business tax return by blending these personal expenses into the business’s cost of goods sold. The Audit Division of the IRS referred the matter to the Criminal Investigation Division and we were successful at convincing the Criminal Investigation Division to discontinue its investigation and return the matter to Audit.
Stuart B. Ratner, P.C. represented a taxpayer accused of filing a false offer in compromise. We quickly convinced the investigating Criminal Investigation Division agents that the offer contained no false or misleading information which resulted in CID dropping its inquiry.