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  • IRS Senior Trial Attorney
    Successfully Represented Clients Before The IRS While Working For Deloitte Tax LLP

    ABOUT

    Vic Abajian founded Abajian Law in 2006 to build on his early success as an IRS Senior Trial Attorney. Vic has worked on all types of tax issues ranging from individuals with less complex tax problems to major publicly traded corporations with very complex tax controversies involving millions of dollars. He is highly respected by the IRS and other tax practitioners and looks forward to helping you quickly and successfully resolve your tax issues.

    Vic was a Senior Trial Attorney with the IRS Office of Chief Counsel in Laguna where he was recognized by the Department of Treasury for exemplary service. As a Senior IRS Trial Attorney, Vic successfully:

    • Represented the IRS Commissioner before the United States Tax Court in all phases of litigation and trial;
    • Advised IRS Exam, Appeals, and Collection groups on substantive and procedural issues relevant to the assessment and collection of tax for individuals, limited liability companies, partnerships and corporations; and
    • Worked as a team leader in the Abusive Tax Avoidance Transaction program and helped develop I.R.C. ยง 6700 promoter cases for prosecution by the Department of Justice.

    While at the IRS, Vic gained valuable experience working on tax audits of individuals, estates, and small and medium-sized businesses. He also worked on many complex Estate and Gift tax cases involving difficult valuation/discount issues including family limited partnerships and limited liability companies. He is highly experienced at working with valuation experts to resolve these types of issues. Vic also worked on numerous cases involving the use of indirect methods by the IRS to establish unreported income and tax fraud.

    After working for the IRS, Vic was hired by Deloitte, LLP, a “Big 4 accounting firm” located in Los Angeles. He joined Deloitte’s Tax Controversy group where he successfully:

    • Resolved complex tax controversies for wealthy individuals and large corporations before the IRS;
    • Drafted protests, responded to Notices of Proposed Adjustments, Information Document Requests and other inquiries by the IRS;
    • Advised Deloitte’s various tax groups about IRS practice and procedure and substantive tax law;
    • Conducted extensive tax research for difficult and novel tax issues; and
    • Worked on a broad range of issues involving different industries.

    Vic used his IRS experience to help Deloitte’s clients prevail in audits. In one case, the IRS was attempting to recreate the income of a couple. Vic worked closely with the Revenue Agent and the audit resulted in a no-change. In another case, the IRS was asserting over $10 million in adjustments against a relocation company, alleging that the customer deposits were income. Vic drafted a write-up for the fast-track mediation and worked with a team of Deloitte folks and an outside law firm to resolve the audit with a no-change by the IRS.

    Prior to working at the IRS, Vic was hired by a boutique tax firm in Los Angeles.. There, he successfully represented clients with tax problems before the IRS, FTB, and EDD, formed and advised business clients about LLC’s partnerships and corporations, reviewed tax planning strategies and provided estate planning services.

    • Georgetown University Law Center, Master of Laws (LL.M.) in Taxation with Distinction;
    • Dean’s List (Top 10%), Southwestern University School of Law;
    • Associate Editor, Southwestern University School of Law, Law Review;
    • President, Tax Law Society; and
    • Awarded summer internship with the Office of Chief Counsel, IRS, in Los Angeles.

    Due to his highly specialized experience, knowledge and invaluable contacts, Vic is extremely successful in negotiating favorable settlements on behalf of his clients. Vic’s ability to reach favorable settlements is based not only on his mastery of the law and facts, but also on his ability in taking cases to trial. The IRS and State Taxing Authorities are cognizant of and respect the fact that he is a former Senior IRS Trial Attorney and is willing to go to trial if necessary. Further, Vic has been able to successfully resolve many complex audits by bringing together expert CPAs, high-level expert witnesses and other professionals to execute a well thought-out strategy.

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