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H&A Wins Self Dealing Penalty Abatement

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By Joe Nagel, Esq., LLM, CPA

The IRS confronted our client with an assessment of over $700,000 in self dealing transaction penalties under Internal Revenue Code Section 4941 for its dealings with a private foundation.  H&A obtained a full abatement of the assessed penalties through hard work,  creative thinking, and attention to detail.  This was a collaborative effort by our tax controversy team and is a testament to the wide ranging skills and knowledge offered to our clients.

We cannot guaranty abatement of penalties.   The success or failure of a request or claim for penalty abatement depends on the facts and circumstances of each individual case.  If you need help dealing with the IRS, please email or call us at info@hoffmanestatelaw.com or 404.255.7400.


  • Joe Nagel

    Joe joined Hoffman & Associates in 2000 and became a partner in 2007. He is licensed to practice law in Georgia, Florida, North Carolina, and Ohio and is also a Certified Public Accountant. Joe serves clients in the areas of estate planning, corporate law, employment law, mergers and acquisitions, succession planning, income and estate tax planning, and tax controversy.

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