Approached by client 10 days prior to scheduled Tax Court trial date.  All-hands on deck preparation and presentation of full documentation and legal analysis.  Presentation to Tax Court, subsequent negotiation with IRS Counsel and favorable negotiated settlement after renewing favorable negotiating position with defensible positions at trial.

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.