Picard v Commissioner (9th Circuit, 1999). This case involved representing 375 disabled police and firefighters in an attempt to overturn a Tax Court opinion denying them tax-free status of their disability pension. The IRS agreed to accept the disability income designation and refund our clients over $15 million.
However, the IRS subsequently ruled that some of the claimants remained ineligible. The case returned to court, and ultimately broke new ground by applying the principals of class action suits for the first time in a tax case.
The IRS finally conceded
the issue, which resulted in another $5 million or more in tax-free benefits
for the police and firefighters.
U.S. v Golden A.D.A.
(Northern District, USDC, 1997). This case involved a jeopardy assessment
of slightly under $100 million against a Russian Government sponsored
diamond processing company located in San Francisco. The Firm was hired
as a special tax counsel and was successfully representing the debtor
until an involuntary bankruptcy petition was filed.
Undisclosed client v. Commissioner (Tax Court, 1999). In this case, the taxpayer was faced with an assessment of several million dollars involving the transfer of assets to foreign trusts and partnerships. The Firm successfully obtained a dismissal of the case from the IRS on the first day of trial.