The focus of Mr. Jones is to resolve matters in the most economical manner at
the lowest level of the IRS administrative process. This means trying to resolve
IRS matters at the district level or the Appeals Office before filing suit
against the IRS. Set forth below are representative cases handled by Mr. Jones:
1. After audit the IRS issued a statutory notice of deficiency alleging that the
taxpayers were liable for taxes and penalties totaling $10,528,232 plus
interest. Successful negotiations with the IRS Appeals Office and IRS Counsel
resulted in a full concession by the IRS.
2. During audit the IRS proposed to disallow a loss for worthless stock. The
total amount of the proposed assessment was $133,000 plus interest. Negotiations
with the IRS Appeals Office resulted in an allowance of 70% of the stock loss in
the year at issue and the carry forward of the balance to future years.
3. The IRS proposed to treat certain workers of the taxpayer as employees and
not independent contractors. The proposed assessment was $180,764 plus interest.
Successful negotiations with the IRS Appeals Office resulted in a no change and
continued treatment of the workers by the taxpayer as independent contractors.
4. Upon audit the IRS determined the taxpayer’s farm was a hobby and no expenses
were deductible. After a proposed assessment of $111,183 plus interest, the IRS
Appeals Office conceded that the taxpayer was in the farming business and
entitled to deduct all of the claimed expenses.
5. After a criminal investigation and a lengthy audit, the IRS proposed
substantial deficiencies against the taxpayers, including the fraud penalty. A
settlement favorable to the taxpayers, including a concession of all penalties,
was obtained after filing suit against the IRS.
6. The IRS upon audit proposed additional income taxes against the taxpayers in
the amount of $153,022 plus interest. The issues involved included a
cancellation of debt issue and other issues involving losses. The IRS Appeals
Office made a full concession after reviewing the taxpayers’ protest.
7. The taxpayer had been assessed a trust fund recovery penalty in the amount of
$94,684. By the time the taxpayer consulted Mr. Jones, the amount owed,
including interest, was in excess of $100,000. An offer was made based on doubt
as to liability. While the IRS District Office rejected the offer, the IRS
Appeals Office settled the liability for $12,500.
8. The taxpayer was assessed substantial penalties for failure to file Forms
5472 (Information Return of a Foreign Owned U.S. Corporation or a Foreign
Corporation Engaged in a U.S. Trade or Business) pursuant to Section 6038A of
the Internal Revenue Code. After filing suit against the United States, a
settlement favorable to the taxpayer was reached.
9. Upon audit the IRS proposed an assessment against the taxpayer in the amount
of $57,842 plus interest. The issue involved was whether the taxpayer was
entitled to deduct guarantee fees paid to its shareholders for them guaranteeing
loans to the taxpayer. A successful Appeals Conference resulted in a full
concession by the IRS.
10. The IRS proposed a trust fund recovery penalty of $64,293 against the
taxpayer. The proposed penalty was fully conceded by the Revenue Officer after a
full presentation of the facts involved.
11. Successful in having almost $20,000,000 in penalties abated which were
assessed against the taxpayer.