Resolved November 2026
A successful outcome for our client: of the roughly $480,000 the IRS originally sought, only about 2% remained in the final Tax Court decision.
Client situation
A taxpayer received a Notice of Deficiency involving a substantial constructive dividend issue and disputed the IRS's position.
The matter ultimately proceeded to the U.S. Tax Court.
Our involvement
VG CPA PC worked extensively with the taxpayer's legal team. Tax Court counsel was retained to represent the taxpayer before the Court.
- Analyzed the IRS adjustments
- Reviewed supporting documentation
- Assisted with factual development
- Prepared and organized financial records
- Supported the taxpayer's Tax Court defense strategy
Outcome
After extensive negotiations, and with the supporting documentation our team prepared provided to the IRS Office of Chief Counsel, the parties reached a settlement.
The Tax Court decision reflected a substantially reduced deficiency and penalties.
Result
- The IRS originally asserted approximately $480,000 in additional liability.
- The final settlement reduced the proposed amount by approximately 98%.
- The Tax Court decision reflected a substantially reduced deficiency and penalties.