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.

Analysis of individual taxpayer purchase of REMIC I/O strip with unforeseen and negative tax consequences. Guiding return preparer through corresponding entries and explanation for federal returns.