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Representative Matters

TAG is proud to present some of our recent accomplishments. In addition to TAG's many client successes, team members are actively involved in many professional organizations and throughout our communities. TAG client success stories are many and varied; below is a small sampling of recent activity.

Tax Representation Services

• Represented a boutique law firm before the IRS Appeals Division and subsequently before the IRS Office of Chief Counsel in connection with the examination of five years of corporate income tax filings prepared by a regional CPA firm resulting in the reduction of tax, interest and penalty of more than $1.2 million.
• Represented a global law firm with more than 500 attorneys in offices across the United States and around the world before the State of Washington, Department of Revenue in connection with the examination of business, occupancy and personal property tax filings resulting in the avoidance of $7,500 in penalties.
• Represented an international law firm with offices throughout the United States and abroad before the Audit Bureau of the Illinois Department of Revenue and secured a "no change" income tax report.
• Represented a large Philadelphia based, multi-state, internationally recognized design firm providing professional services in the disciplines of architecture, engineering, interior design, planning and landscape architecture before the Utah State Tax Commission and negotiated the abatement of more than $20,000 in penalties resulting from late payment of non-resident trust fund taxes.
• Represented a large Philadelphia-based architectural firm before the Government Entities Compliance Unit of the IRS in a new Voluntary Classification Settlement Program, which resolved classification of workers for employment tax purposes and obtained substantial relief from federal payroll tax liabilities, including waiver of interest and penalties.
• Represented a national chain of clothing stores before the City of Philadelphia Law Department, arranged filing of five years of unfiled tax returns and successfully negotiated a 30 percent reduction in tax, interest and penalties.
• Represented a real estate agent before the Advisory Group Division of the IRS resulting in a discharge of federal tax lien, avoidance of foreclosure of real property, consummation of a short sale, transfer of clean title and protection of real estate agents license and future career pursuits.
• Represented a manufacturer in a Pennsylvania sales and use tax audit and subsequently at the appeals level, resulting in a reduction in the tax assessment by more than $250,000, followed by an application for abatement with Pennsylvania Board of Finance and Revenue which resulted in abatement of penalties in excess of $235,000 for a combined savings to the client of $485,000.
• Represented an officer of a Philadelphia-area construction company and obtained decision dismissing, with prejudice, a $1.5 million responsible officer/trust-fund recovery penalty action brought by the Philadelphia Revenue Department against various officers of the company for unpaid wages and business-privilege taxes.
• Represented a retiree before the Collection Division of the IRS and arranged the elimination of about $35,000 in income tax resulting from an erroneous assessment made by the IRS.
• Represented a golf course before the Collection Division of the IRS and negotiated the abatement of a civil tax penalty of more than $14,000 as a result of failure to file required tax returns.
• Represented a decedent before the Examination Division of the IRS resulting in an income tax savings of more than $100,000.
• Represented a supplier of communication systems and services before the Examination Division of the IRS and secured a "no change" income tax report.
• Represented a lawyer before the New York Department of Finance and Revenue resulting in a "no change" income tax report.
• Represented a college professor of one of the most prestigious universities in Pennsylvania before the Examination Division of the IRS resulting in a "no change" income tax report.
• Represented a regional law firm before the City of Philadelphia resulting in the reduction of a tax deficiency assessment from $250,000 to $50,000.
• Representation of a liable spouse before the Criminal Investigation Division of the IRS, avoided criminal prosecution, significant reduction of tax liability, submission and acceptance by IRS of Offer in Compromise.
• Represented a seller of sports memorabilia before the Examination Division of the IRS and secured a "no change" income tax report.
• Represented a client before IRS and successfully compromised a tax liability of more than $4 million for less than $350,000.
• Represented an international law firm before the City of New York Tax Appeals Tribunal resulting in a reduction in New York City unincorporated business tax from $230,000 to $25,000.
• Represented an international law firm before the Chicago Department of Revenue and secured a "no change" sales tax report.
• Represented a lawyer before the Appeals Division of the IRS and negotiated a compromise of a $2 million tax liability for $110,000 and a similar compromise with the Commonwealth of Pennsylvania whereby a $120,000 liability was settled for $20,000.
• Represented a physician before the Collection Division of the IRS and arranged the release of levies, a reduction in assessed tax by approximately $400,000 and elimination of interest and penalties of approximately $50,000 after the discovery of an IRS calculation error.
• Represented a personal financial planner before the Collection Division of the IRS and negotiated a compromise of a significant federal income tax liability resulting in a savings of more than $700,000.
• Represented a partner of a real estate development company before the Collection Division of the IRS and successfully convinced the IRS that the partner was not a responsible officer resulting in elimination of more than $400,000 in trust fund tax assessments and related interest and penalty.

Litigation Consulting Services

• Conducted a forensic examination for one of the largest international shipping and transportation companies, including performing asset investigation services identifying hidden assets in a $1.5 million vendor fraud matter. Also performed an extensive Successor Liability, Alter Ego and Piercing of the Corporate Veil analysis in an effort to assist in recovery.
• Represented a spouse in a marital dispute and conducted asset locator services identifying over $100 million in hidden assets resulting in a significant marital settlement.
• Assisted the Office of Federal Housing Enterprise Oversight (OFHEO) in conducting its extensive and complex Special Examination of Fannie Mae's manipulation of accounting and earnings to trigger bonuses for senior executives. The examination resulted in a comprehensive report of more than 340 pages and an agreement by Fannie Mae to pay $400 million in penalties and enter into a significant plan of remediation.
• Performed a damage analysis and provided an in depth analysis of an opposing expert's damage report in a trademark infringement case related to the unlicensed distribution of certain auto parts resulting in favorable result to client.
• Conducted a forensic examination for an international asset management organization, including interviews, and identified employee fraud and resulting economic damages in excess of $100,000.
• Represented a spouse in a marital dissolution and prepared a comprehensive net worth analysis and business valuation used to secure a favorable settlement.
• Represented an estate in a wrongful death matter, conducted in-depth interviews, prepared extensive damage calculations, and assisted counsel in obtaining favorable result for the client.
• Developed extensive damage models and performed complex damage analysis calculations which were utilized by a Director and Officer insurance carrier in defending a claim arising from a securities fraud litigation matter involving a national telecommunications company resulting in favorable outcome for client.
• Prepared an extensive analysis of reasonable salaries and lost profits in a class action litigation matter involving an international chemical company resulting in favorable decision for the client.
• Prepared a report for a national insurance company quantifying the relative and absolute damage exposure faced by Underwriter Defendants following an alleged accounting fraud of an international energy company in a class action securities matter.
• Conducted a suitability analysis and alternative investment strategy analysis and provided a report regarding the damages sustained by a plaintiff as a result of alleged professional negligence by a broker resulting in favorable decision for client.
• Performed a compliance audit for a special committee of a large real estate investment trust to determine amounts due former shareholders under various agreements.
• Performed an extensive successor liability analysis for an automobile dealership resulting in a favorable decision for the client.
• Prepared an extensive shareholder oppression claim analysis including damage assessment in connection with an international technology company resulting in a favorable settlement for shareholders.
• Performed a comprehensive forensic investigation of employee fraud in a retail business resulting in a favorable result for the client.
• Prepared a comprehensive damage analysis in connection with an employee stock option plan, including alternative investment analyses and analysis of fiduciary breaches resulting in a favorable outcome for client.
• Developed complex damage models to measure lost profits incurred by a regional brokerage firm as a result of published defamatory statements resulting in a favorable outcome for client.
• Prepared a comprehensive damage analysis for a national food retail and distribution company and served as a consultant to the experts for counsel resulting in a favorable outcome for client.

Accounting, Financial and Management Advisory Services

• Conducted an improvement study for a regional medical services provider and prepared a report addressing corporate strategy, underlying systems and processes including cash management, receivables, collections and OSHA compliance. Post implementation, client enjoyed significant cost savings and increased profits.
• Conducted an analysis of application of generally accepted accounting principles for a governmental entity related to capital v. operating lease reporting resulting in a favorable leasing arrangement for client.
• Conducted an improvement study for a facilities management company resulting in the implementation of recommended changes to cash and receivable management systems and improved internal controls.
• Served as entrusted agent to an international real estate developer with more than $50 million of escrow funds under management.
• Conducted a license agreement and systems review of an international medical products manufacturer resulting in the identification of unpaid and underpaid royalty fees of approximately $300,000.
• Analyzed various financial reporting models under generally accepted accounting principles for an international technology company in support of counsel recommendations in due diligence proceedings related to an international acquisition.
• Served as court appointed accountant to the bankruptcy trustee in a securities firm bankruptcy matter and prepared a comprehensive accounting and managed the liquidation disbursement process for the trustee.
• Performed a policy and procedure review for a law firm, including analysis of office procedures, cash management, collections and financial reporting resulting in increased operational efficiency and profitability.
• Prepared a comprehensive analysis of the reasonableness of the salaries of employees and shareholders of a physician practice based on standards established by the IRS and courts.

For More Information

For additional information, please contact Michael A. Gillen, Director of the Tax Accounting Group, or the Tax Accounting Group practitioner with whom you are regularly in contact.