Tax Planning and Tax Controversy:
Taxpayer was improperly assessed penalties due to late filing and payment. However, the taxpayer was entitled to disaster relief tied to two different states. The coding procedure was very nuanced with the IRS and there was a lot of negotiation involved. We were able to get through to the proper channels and ensure that the account was coded properly. This resulted in approximately $44,000 reduction in IRS penalties for the taxpayer.
- Business taxpayer was erroneously assessed over $65,000 in IRS back up withholding. We were able to work with the client, IRS representatives and taxpayer advocate service to get the assessment reversed. This resulted in a zero-balance due for IRS backup withholding.
- A taxpayer claimed a Qualified Charitable Donation on a tax return. The IRS was going to disallow the carry-over donation. Our Hoffman & Associates team assisted the taxpayer in
providing the correct response to the IRS. Our assistance aided in obtaining a
no change result for the taxpayer and allowance of the Qualified Charitable
Donation.
- A foreign taxpayer was referred to our firm due to the passing of a spouse. The decedent had a US based account. The foreign taxpayer was not aware of the account. It was determined that the taxpayer had a US estate tax return filing requirement. Our firm assisted with determining the correct taxable estate amount based on US treaty law and filing the return. The taxpayer also needed assistance with obtaining a transfer certificate, in order to gain access to US based funds. In addition to the tax filing and obtaining the transfer certificate, the Hoffman & Associates team was successful in negotiating an approximate abatement of $1.4 million in IRS tax penalties.
- A taxpayer had several tax assessments due to unfiled tax returns. We assisted the taxpayer with filing past due tax returns both for the taxpayer’s business and individually. After assisting the taxpayer with compliance in filing, we were able to successfully negotiate a waiver of approximately $29K of penalty with the Georgia Department of Revenue.
- Hoffman & Associates was engaged by two entities to assist with filing annual tax returns. Based on tax law change and the form of payment that was used to submit the payments due, the taxpayer incurred approximately $490,000 worth of IRS and state tax penalties. Our team was successful in getting these penalties removed.
- A taxpayer was not aware that there were any unfiled tax returns after their spouse passed. Our Hoffman & Associates team aided the taxpayer in filing all the past tax returns and was successful in getting approximately $97K worth of penalties waived with the Georgia Department of Revenue.
- Our Hoffman & Associates team assisted a business taxpayer in providing the correct information for an IRS request regarding capital contributions to their business. The response provided by our firm to the IRS resulted in a no change to the taxpayer’s return.
- A taxpayer claimed a Qualified Charitable Donation on a tax return. The IRS requested additional information to backup the deduction. Our Hoffman & Associates team assisted the taxpayer in providing the correct response to the IRS. Our assistance aided in obtaining a no change result for the taxpayer.
- Through a collaborative effort between the client, his accountant, and the Hoffman & Associates team, we were able to reduce his income tax assessment from over $160,000 to a mere $436.
- Hoffman & Associates was successful in obtaining a $55,000 abatement for a client after he was assessed late filing and late payment fees by the IRS.
- Hoffman & Associates was successful in obtaining an abatement of penalties in the amount of $56,000 for late payment of taxes after our client’s CPA filed a request that had been denied by the IRS.
- Due to the depth of knowledge and expertise displayed by the Hoffman & Associates team, our client was successful in obtaining an abatement of $103,000 in IRS penalties assessed against the estate for filing a late tax return.
- Due to the extensive effort of the Hoffman & Associates team, an LLC was able to continue operations after the IRS accepted the removal of a wrongful levy. The IRS had placed a $1.5 million lien against each individual of this LLC and if that lien had been satisfied, it would have been catastrophic for the operating business.
- The wide range of skills and knowledge possessed by the Hoffman & Associates tax controversy team helped our client successfully obtain an abatement of over $700,000 in self-dealing transaction penalties under Internal Revenue Code Section 4941.
- Hoffman & Associates successfully obtained an involuntary exchange extension to find replacement property for one of our clients after the IRS had rejected the request for being 18 months past the end of the 3 year replacement period.
High Net-Worth Estate Planning:
- Hoffman & Associates designed an integrated estate and succession plan for a high net-worth client. The value of the estate was $85 million. The plan design included the use of dynasty non-grantor trusts, dynasty defective grantor trusts, family limited liability companies and discounted gifting, self-canceling installment notes, irrevocable life insurance trusts, and grantor retained annuity trusts. The plan reduced estate tax exposure by an estimated $24 million initially, but additional estate tax savings are expected as family wealth accumulates in trusts outside of the estate tax system.
- Hoffman & Associates designed and implemented an estate plan over a period of a decade that has resulted in over $60 million worth of assets held in family dynasty trusts, protected from creditors and divorce and outside of estate tax exposure. The value of the estate initially consisted of a small business worth between $20 and $30 million but has continued to grow substantially year over year. Included in the plan design were dynasty life insurance trusts, dynasty non-grantor trusts, dynasty defective grantor trusts, grantor retained annuity trusts, family limited partnerships and limited liability companies, discount planning and gifting, and self-cancelling installment notes. Over three-fourths of family wealth now resides safely in family dynasty trusts, protected from creditors, divorce, and outside estate tax exposure.
- Through proper planning, creative thinking, and hard work, Hoffman & Associates was able to defend a key client’s estate from an additional $2.4 million in estate taxes assessed by the IRS after an audit.
- Hoffman & Associates successfully settled an estate tax case for $1.25 million saving our client over $8 million in taxes, penalties and interest.
