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David M. Fogel, CPA

Tax Consultant

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My Successes

Over the past several years while working in the private sector, I have successfully resolved several tax disputes for clients. Here is a sample of some of my successes.
 
Prepared a lengthy analysis of a client’s reduction of tax attributes resulting from debt excluded by bankruptcy and insolvency, saving the client more than $90,000 in an IRS audit.
 
Successfully appealed a Federal gift tax audit involving the fair market values of interests in a limited liability company, saving the client approximately $880,000.
 
Successfully appealed a Federal estate tax audit involving the values of several notes receivable, saving the client approximately $150,000.
 
Convinced the IRS to close an audit of a client's tax returns "no change" after the IRS had sent a report proposing nearly $1.9 million in additional tax, penalty and interest.
 
• Defeated the IRS's attempt to dismiss a Tax Court case for lack of jurisdiction in Van Brunt v. Commissioner, T.C. Memo. 2010-220.
 
• Successfully appealed three Federal income tax audits involving reasonable compensation paid to the corporations' officer-shareholders, saving the clients a combined total of over $900,000.
 
• Successfully appealed a Federal income tax audit involving S corporation deductions and debt basis issues, saving the client approximately $140,000.
 
• Convinced the IRS to concede a $20,000 employment tax assessment.
 
• Resolved a Federal estate tax audit involving a family limited partnership, saving the client approximately $915,000.
 
• Convinced the IRS to concede a $380,000 late filing penalty by writing a single letter.
 
• Successfully defended a California income tax audit involving a reverse Section 1031 exchange, saving the client approximately $750,000.
 
• Resolved a Federal gift tax audit involving the value of gifts of interests in a family limited partnership, saving the client approximately $550,000.
 
• Successfully represented the taxpayer in Forste v. Commissioner, T.C. Memo. 2003-103, involving an exclusion from income for amounts received for personal injuries, and was successful in getting the IRS to pay attorneys fees and costs.
 
• Assisted in successfully representing the taxpayer in Byrne v. Commissioner, T.C. Memo. 2002-319, involving an exclusion from income for amounts received under a retirement law that was in the nature of a workmen’s compensation statute, and was successful in getting the IRS to pay attorneys fees and costs.