Appeal of technical aspects of AMT carryover of impact of NOL caused by Miscellaneous Itemized Deduction in subsequent year.   Multiple layers of appeal and involvement of the Taxpayer’s Advocate office resulting in successful outcome for taxpayer on prior year refund.

IRS audit relating to technical application of distributions in excess of outside basis from partnership.  Discussions with taxpayer, research into historical outside basis records and recalculation of potential capital contributions unaccounted for in financial accounting.  Discussions with IRS audit personnel relating to application of at risk rules and distribution taxability, preparation of penalty waiver request based upon reliance on previous tax return preparer.

Audit & appeal (multi-stage through local tax tribunal) of application of bulk rate to contiguously-joined coop unit, research and presentation of administrative precedent and application of same to unusual fact pattern involving prior conjoined use followed by intervening separate use of physically connected units.