Allen and his team have extensive experience in many aspects of tax controversies. Recent assignments included numerous representations of individuals and companies in the IRS Offshore Voluntary Disclosure Program and Initiative. These complex cases required attention to many years of financial transactions to assess and accurately report them to the IRS and many States.
In addition, representations include appeals of IRS Audit findings, negotiations of Offers In Compromise, assistance in IRS audits and assisting Counsel in criminal tax investigations as a Kovel retained CPA.
Often, the criminal matters result in conferences with Assistant U.S. Attorneys in conjunction with counsel to address tax aspects of cases.
We prepare delinquent returns, amended returns and consult on appropriate tax positions on transactions.
The range of work entails Income Tax, Estate Tax, Corporate Tax, International Tax Issues and compliance with U.S. Treasury FBAR (Foreign Bank Account Reporting).