Client came to Abajian Law with an undisclosed Swiss bank account that contained over $1 million. It was determined that an OVDP was the proper way to resolve the issues with the IRS. After meeting with the client several times and getting to really know every intricate detail of his life, Vic was able to craft a very persuasive memo for why the taxpayer’s behavior was non willful and thus, they should only be subject to the 5% penalty instead of the 27.5% minimum. The IRS OVDP auditor agreed and the client saved hundreds of thousands of dollars
Taxpayers had undisclosed foreign accounts (including those in Russia) that contained over $ 1 million. At the time, the only option was an OVDP and thus, the taxpayers decided to proceed on that basis. Vic worked with the taxpayers and their CPA and conducted an extensive investigation into the facts, including interviews with the prior tax return preparers and financial advisors. Vic crafted a detailed and persuasive nonwillful penalty memo which was accepted by the IRS so that the penalty on high balance was reduced from 27.5% to 5%. Vic, however, recommended that the taxpayer “opt out” of the OVDP and pursue a 0% penalty, executed a well-reasoned strategy and was successful. Vic convinced the IRS to accept a 0% penalty which saved the taxpayers hundreds of thousands of dollars.
In 2017, we assisted client with a streamlined disclosure for unreported accounts/asset in India. Client had approximately $500,000 in foreign assets.
In 2017, we assisted client with a streamlined disclosure for unreported account in India. Client had approximately $1 million in foreign assets.
“I am writing this email to thank you for your kindness and for taking time to discuss my case and for all the advice. It helped relieve my anxiety and I am grateful to you for that.
Thanks once again.”
Clients were under examination and had an undisclosed Swiss Bank account with a high balance of over $2 million and a business venture in another foreign country. Vic was able to work with the Revenue Agent (after several face-to-face meetings) and guide the clients through a successful interview with the Revenue Agent, demonstrating the favorable facts. We were able to successfully submit Form 5471 and Foreign Bank Account Reports (FBARs) to the Internal Revenue Service (IRS) and close the case with zero penalties, although the Revenue Agent initially indicated that a 50% FBAR penalty was appropriate.
Client was assessed with a substantial penalty for late filing of Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. Client received a substantial inheritance that was not reported to the IRS by their tax return preparer, and the nondisclosure was made even worse by the preparer’s inexperienced attempt to come into compliance. The preparer then fumbled the representation before the IRS. We were retained to protest the findings of the revenue agent and request that the penalties be abated. After interviewing the client in detail several times and conducting substantial due diligence, we drafted a persuasive protest to IRS Appeals and resolved the case with a full concession by the IRS with no penalties due.
The IRS thought one of my businesses was a hobby, however, Vic Abajian’s stellar reputation with the IRS, know-how as a former IRS attorney and very technical understanding of the Tax Code got me an amazing result. They are 100% results driven. I even paid them a bonus for outstanding results.”
Working with a prior tax resolution firm, Taxpayer received proposed tax assessments and penalties totaling $402,433. Abajian Law protested the case to IRS Appeals and settled the case for a no-change ($0) after a face-to-face meeting with Appeals. Taxpayer’s final resolution also allowed a net operating loss to apply towards future years and for his business to not be limited by the hobby loss rules of I.R.C. section 183.
Taxpayer walked into Abajian Law with proposed tax penalty of $514,807 after going through an audit defended by two prior power of attorneys. After petitioning the United States Tax Court and working in conjunction with IRS Counsel and an IRS Examiner, Taxpayer stipulated to pay only $52,456.
The original IRS examiner proposed assessments for passive activity loss limitations for rental properties and additional K-1 income from a flow through entity. Abajian Law was able to reduce the proposed assessment substantially and request other adjustments in Taxpayers favor which were missed on the original filed tax return.
Taxpayer’s audit handled by another power of attorney resulted in $179,640 of tax and penalty after an extensive audit. Taxpayer came to Abajian Law who petitioned the United States Tax Court; stipulation was entered for the case and all issues were resolved for $15,239.
Taxpayer was disallowed ordinary and necessary business expenses stemming from a pass through entity and Taxpayer was not able to substantiate basis in the pass through entity during audit. Abajian Law became involved and helped Taxpayer substantiate expenses and prove up basis.
Taxpayer received a notice of proposed deficiency from the Franchise Tax Board stating that Taxpayer could not take the Qualified Small Business Stock Gain exclusion after selling his corporation. Taxpayer went through audit, a protest, a settlement hearing trying to fight the proposed assessment. Abajian Law requested a hearing with the Board of Equalization and drafted briefs in preparation for the hearing. Weeks before the hearing, Abajian Law was cc’d a memorandum written to the BOE stating, “after further review of the arguments raised by appellants in their supplemental briefing, the Franchise Tax Board is now prepared to withdraw the $93,007 proposed deficiency assessment for the taxable year.” The appeal was dismissed before the hearing.
Taxpayer (a top commercial broker in Orange Country) received a revenue agent’s report assessing tax penalty and interest totaling $247,924 for taxable years and a letter stating that the examiner was going to open two more subsequent tax years which would also be audited. Auditor was sending the taxpayer endless requests for information. The proposed assessments included proposed additional unreported income, passive activity loss limitations, and disallowances of ordinary and necessary business expenses. Taxpayer retained Abajian Law who quickly had the case reassigned and obtained a $43,077 refund for all four tax years and an apology from a new auditor.
Our past liabilities from tax years 2008 through 2012 totaled $602,276.94. We met with Vic Abajian and Aksel Bagheri of Abajian Law and were impressed. Vic is a former IRS attorney. Aksel is a very smart lawyer with an advanced tax degree from Loyola Law School. They interviewed us in detail and crafted a well thought out position. After they submitted an Offer In Compromise Doubt as to Liability and an Offer In Compromise Doubt as to Collectability, Abajian Law settled our liability for $1,470 during the course of an eight month period. Most of that time was spent waiting on the IRS.We ended up paying less than half a percent of our total liabilities and the fees paid to Abajian Law were very reasonable. We can’t say enough good things about them.”
Father and Mother of United States Marine fighting in Iraq and Afghanistan owed $133,000 of overdue taxes. Taxpayer received hefty severance after leaving his employment, however Abajian Law demonstrated that taxpayer had spent the entire severance on necessary living expenses and would have to continue using the rest of the severance money; the IRS agreed and excluded the severance from the offer amount. Abajian Law submitted an Offer In Compromise Doubt as to Collectability and IRS accepted the offer for $800.
A practicing attorney, Taxpayer with liability of $398,864 walked into Abajian Law with years of unsuccessful negotiation with the IRS and a defaulted installment agreement. IRS accepted an Offer in Compromise Doubt as to Collectability for $85,000. IRS withdrew all tax liens.
They quickly went over boxes of documents that we had and put together an Offer in Compromise on a complex fact pattern that was quickly accepted by the IRS. We can’t thank them enough. They worked on our case throughout the entire process and were very responsive.”
Client worked with prior power of attorney in a failed Offer in Compromise Doubt as to Collectability to settle $391,655 of federal tax liabilities. IRS claimed Taxpayer transferred a property with significant equity away from its reach claiming that the transferee was a nominee and that the transfer constituted a dissipation of assets. Abajian Law appealed examinations’ conclusions to the IRS Office of Appeals demonstrating that transferee was true owner of the property. Abajian Law demonstrated why the quitclaim of property to another taxpayer was not a dissipation of assets in this particular case.
Vietnam Vet and United States Marine with a $65,000 tax liability compromised his liability for $17,660 with the help of Abajian Law who was able to claim fiancé as a “qualified relative” and a member of the household for offer purposes in order to claim enough expense to make offer work. IRS also agreed that contested inheritance was not a dissipated asset. Tax liens were withdrawn allowing client to take out a VA loan to buy his first property in the country he fought for.
Helped client get lien discharges to sell two properties and obtain an Offer In Compromise Doubt as to Collectability.
Reduced tax liability, helped client get a lien withdrawn so that client could sell a house and get all of the proceeds from the sale.
Client received advice from a tax resolution firm to file an Offer In Compromise which would have cost $8,000. Advised client not to file an offer because the statute of limitations on collection was close to expiration. Statutes expired without any collection action whereas an Offer In Compromise would have extended statute period. In addition, our strategy saved the client unnecessary fees.