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Over the years, I have had a number of clients that have been involved with tax controversy issues on a wide range of matters. While we have handled some issues internally at Freed Maxick, I’ve found it much more beneficial to work collaboratively with the legal team of Andreozzi & Bluestein LLP given their vast experience and highly specialized approach. Since many of their attorneys have worked for the IRS, their in-depth knowledge of how to strategically approach every issue has been a great asset to us. They have provided tremendous value to our clients, and they have been instrumental in helping them receive positive outcomes. Their team is tenacious, committed, and take their work personally. I highly recommend Andreozzi & Bluestein for your tax controversy needs.
We first worked with the team at Andreozzi Bluestein 7+ years ago, when we got them involved in a very complicated client matter. Since the very beginning, Andreozzi Bluestein has provided nothing less than exceptional client service, and they have come through with many winning results. The entire team is timely, responsive, easy to get along with, bright, intelligent, and compassionate. Most importantly they are always willing to fight for their clients to the end. Our shared values give us faith in their entire team and we have no hesitation in referring clients to them, since we know they are going to treat and handle them in the same manner that we would. The Andreozzi Bluestein team is organization of true professionals from top to bottom. We are proud to be associated with them, honored to work with them, and thankful for the extended education they have provided us on complex issues.
Throughout my tenure in Public Accounting and now with my own firm, I have referred many clients to Andreozzi Bluestein, LLP to assist them with their tax controversy matters. Our goal is always to provide the best possible service to our clients and while we have handled some controversy matters on our own we find it is much more beneficial to partner with specialists in matters that require more in-depth knowledge and skill. The professionals at Andreozzi Bluestein have that in-depth knowledge and skill when it relates to tax controversy which enables them to bring unique solutions to our clients. We are very pleased with the service Andreozzi & Bluestein has provided to our clients, and we would highly recommend them to other accountants who have clients experiencing issues with the IRS.
I’ve had a number of clients over the past few years that have had significant issues with the IRS, ranging from a failure to report foreign bank accounts to failure to file tax returns for a number of years. In each case, the attorneys at Andreozzi Bluestein were there for my clients, handled their cases with complete professionalism, and ultimately obtained great results. The attorneys there know how to handle tax controversies because that’s what they do each and every day. I’m happy to refer those cases to them because I know it will be handled right the first time, and they will use the best possible legal strategy to achieve the best result for my clients. It’s also comforting to know that I can simply pick up the phone to talk to them about how to handle an issue and they are there to help – without billing me just to answer my question. They truly are great partners that I can rely on any time. I highly recommend the attorneys at Andreozzi Bluestein to any practicing tax accountant who has a pressing client tax controversy matter.
I have had multiple opportunities over the past 10 years to work with the Attorneys at Andreozzi Bluestein. Whether it was a “quick” phone call for guidance, or assistance on a project, their expertise and attention have always been beyond expectations. Two specific situations with new clients come to mind where their experience greatly helped achieve a positive result….one, they successfully worked through the Offer in Compromise process and were able to significantly reduce the Taxpayers Liability. The other, they were able to obtain significant reductions in late filing penalties on a Gift Tax Filing situation. I’ve found all of the individuals that I’ve worked with at Andreozzi & Bluestein to be focused and efficient while remaining fair and sensitive with their fees. I would not hesitate to call on them again and would definitely recommend them to my clients should the need arise.
Andreozzi & Bluestein is a stellar example of the professional relationships we trust. As a small accounting firm providing tax and consulting services, Daitz & Burke relies on the collaboration with our clients’ attorneys, financial advisors and internal management team. It is the team approach of cooperation and trust which builds strong and enduring relationships with our clients. Andreozzi & Bluestein’s extensive experience and expertise in all aspects of US tax controversy including foreign reporting requirements, and compliance has proven to be extremely valuable to us and our clients. We highly recommend them as a great resource when facing issues with taxing authorities.
The tax practice at Dopkins and Company is fortunate to have a sophisticated client base that requires specialized knowledge and experience. Over the years I have had the opportunity to work with the professionals at Andreozzi, Bluestein, LLP. The firm’s attorneys have consistently met our expectations from a personal and professional perspective. The firm has demonstrated technical leadership in complex areas and has a unique ability to relate to clients and meet their customized needs. The firm’s relationships and experience in the area of cross border taxation has proven to be an extremely valuable resource.
Andreozzi Bluestein, LLP is a professional firm with exceptional expertise. I highly value the accessibility and ability of their partners to provide timely and efficient advice and answers. When my international clients have assessments or potential assessments related to late or non-filing of returns and reports and are facing large penalties for non-compliance, I turn to Andreozzi Bluestein, LLP without hesitation. Regardless of the scenario, they have been there before. I would absolutely recommend Andreozzi Bluestein, LLP without hesitation.
I want to genuinely thank you for the “over and above” work you have done on our behalf. From the beginning of our work together it was obvious there was something unique about the high caliber of your work, your overall level of knowledge, and your strong and creative strategic skills. These attributes, in conjunction with your knowledge of IRS rules and regulations, and your firms’ strong values orientation focused on customer service and genuine concern for your clients’ well-being, made our experience with Andreozzi Bluestein one of the best we’ve ever encountered It is rare to work with a firm that has a such a good balance of both technical and interpersonal/personal skills. It has been a pleasure working with you and your team and we appreciate all you have done for us!
The professionals at Andreozzi Bluestein have a unique expertise in their ability to handle various Federal and State tax matters. It’s this experience and the deep trust I have in them, that has been a tremendous help to me and has enabled me to expand my practice by taking on clients with very complex issues. The collaborative nature of our relationship, and the pride they take in ensuring the best possible outcome for our clients, gives me a great deal of confidence that I have the right attorneys on my team when dealing with Federal or State Tax authorities.
Andreozzi Bluestein is an excellent team to work with. With a wealth of experience in tax law, they have provided us and our clients with tremendous support when we’ve encountered tax controversy issues, and I feel confident that they are going to handle our client’s needs appropriately and efficiently. I’m always happy to work with them as varying needs arise, and would never hesitate to contact them for advice or support with a client matter.
The attorneys at Andreozzi Bluestein LLP have a wealth of experience handling issues with the IRS and State taxing authorities. We frequently work with CPA’s, Attorneys, and Financial Advisors to solve tax problems for their individual and corporate clients. Click on any of the links below to read about some of the successful outcomes we’ve achieved for our clients.
Legal Issue: Disputed Income on Individual Tax Return
Category: Income Tax
Referred by: CPA Firm
Services: IRS proposed over $1 million deficiency as a result of disallowed substantiation and fraudulently omitted income on the individual taxpayer’s Schedule C and Schedule E. We petitioned the U.S. Tax Court and were referred to IRS Appeals for settlement consideration.
End Result: The Appeals Officer accepted our substantiation, substantially reduced the omitted income adjustment and abated the fraud penalty. Our efforts reduced the ultimate deficiency by over 96% to approximately $35,000.
Legal Issue: IRC 280A and Regulations- Disallowance of expenses related to business use of a personal residence. IRC 6662- Negligence Penalty
Referred by: CPA Firm
Services Performed: Client owned properties with multiple dwelling areas in two separate states, living in part of one of the properties and his son lived in part of the other property for five months in one of the years in question. The client rented out the remainder of the properties. The IRS disallowed all the rental expenses and losses and asserted penalties. In addition, the client’s original accountant became incapacitated and lost much of the client’s documentation. We worked in conjunction with a new CPA firm in preparing schedules reflecting the actual business use of the properties and properly allocating expenses under IRC 280A, so that the records were clear to the IRS. Finally, we analyzed and uncovered multiple mistakes made by the IRS in their initial computations.
End Result: We reached a very agreeable settlement with IRS Appeals saving the client over $25,000. Additionally, the CPA firm retained the client for future tax return preparation.
Legal Issue: Improper application of Sales Tax to nontaxable items
Category: Sales Tax
Services: New York State assessed a sales tax liability against a food vendor on amounts that included, inter alia, payments from other vendors for rent, royalties, and paper products that are not subject to taxation.
End Result: We obtained a courtesy conference to reopen the audit and successfully reduced the assessed amount by over $100,000.
Legal Issue: Client Schedule C Deductions were disallowed.
Category: Income Tax
Services Performed: Represented individual client with substantial Schedule C income before office audit. The IRS adjustments increased the client’s income by approximately $200,000 prior to our representation.
End Result: Once we were involved, we were able to work with the IRS examiner to ensure proper credit was given for all expenses. We were able to reduce the adjustments by almost $100,000.
Legal Issue: Non US Citizen failure to pay US taxes
Referred by: CPA.
Services Performed: This non-citizen performed consulting work in the U.S., thereby generating taxable income which was left unpaid. Client no longer lived or worked in the U.S., but wanted to address his IRS debt. We submitted an Offer in Compromise based largely on the client’s assets and income in his home country. The Offer was denied as the Specialist believed that the client had the financial means to pay in full. We took the matter to the IRS Office of Appeals, and demonstrated how a bankruptcy in the U.S. would potentially eliminate and/or reduced the tax debt, as well as how the IRS’ collection options were limited.
End Result: The end result was the Offer being accepted at its original amount, thereby saving the client over $166,000.
Legal Issue: Failure to file Tax Returns / Offer in Compromise executed
Referred By: CPA Firm.
Services Performed: Taxpayers, a couple with two minor children failed to file income tax returns for several years. They worked with an accountant to file back returns which resulted in IRS liabilities exceeding $729,000. Our clients had been unemployed for a period of time and were unable to make any payments, and their house was the subject of a foreclosure action. The husband died suddenly, leaving the wife a young widow facing a large tax obligation and a home foreclosure. Shortly thereafter, she began working in her field of expertise but at an entry level salary which only covered a fraction of her day to day expenses.
End Result: We prepared and submitted a federal Offer in Compromise, contesting the amount owed based on our client’s current income, limited assets, and dire circumstances. We were able to reduce the amount owed to the IRS by over 98% resulting in an accepted offer amount to the Taxpayer of only $9,750.00. We were also able help resolve the foreclosure action.
Legal Issue: Chapter 7 Bankruptcy / Offer in Compromise executed
Referred By: CPA Firm.
Services Performed: Our client was a retired skilled tradesman. He had IRS tax debt in excess of $150,000. His home was in a foreclosure action and he also had state income tax debt. Substituted tax returns were filed by the IRS for two of the years involved, amounting to approximately $140,000 of liability, with about another $15,000 in liability for returns which were filed by our client.
End Result: We filed Chapter 7 bankruptcy for our client. His state income tax debt and the approximate $15,000 in federal taxes (for filed returns) met the requirements for dischargeability and were discharged in the bankruptcy action. The larger amount, due to substituted tax returns filed by the IRS was not discharged in the bankruptcy. Our client did not want to save his house from the foreclosure but the bankruptcy prevented the possibility of any deficiency in the action from being assessed to our client as income for income tax purposes and also prevented the foreclosing lender from seeking payment on the likely deficiency which would have resulted from the foreclosure.
We also had to resolve the IRS taxes which survived the bankruptcy, and we drafted and submitted an Offer in Compromise. The Offer of $14,200 on approximately $140,000 of tax liability was accepted by the IRS.
Legal Issue: Penalties for untimely filing
Referred by: CPA Firm
Services: The IRS imposed automatic $10,000 penalties against a corporate taxpayer with foreign owners for untimely filing Forms 5472 for three consecutive years. Our office submitted a reasonable cause letter arguing, inter alia, that the death of the founder of the family-owned corporation, along with a storm that destroyed documentation needed to prepare the returns, warranted an abatement of the penalties.
End Result: We successfully resolved the matter with IRS Appeals for a single $2,000 penalty over the three-year period.
Legal Issue: Aggressive Collection Efforts by IRS
Referred by: Attorney
Services Performed: We represented a couple in a Chapter 7 bankruptcy to help curtail aggressive collection efforts by the IRS. The Bankruptcy Trustee believed the filing was abusive on several grounds, primarily a high monthly “disposable” income of the clients. We successfully rebutted this argument on the basis of the Bankruptcy Code’s “means test” protocol. The Trustee also believed the filing was in “bad faith” and not deserving of a discharge. We provided a detailed accounting, and also successfully argued that the Debtor could seek to discharge other debts in order to devote resources to his non-dischargeable criminal restitution. The Trustee backed off of any further objections.
End Result: Both Debtors were allowed to receive discharges, and their personal obligation on over $80,000 in Federal tax debt was eliminated. In addition, the IRS did not seek post-discharge enforcement of its lien, resulting in Debtors maintaining significant equity in theirassets.
Legal Issue: IRS Refund taxability in Chapter 7 Bankruptcy
Referred by: Attorney
Services Performed: We represented an individual in a Chapter 7 bankruptcy for the purpose of eliminating non-priority tax debt. The Debtor received a large pre-petition tax refund which he claimed as exempt, thereby allowing him to shield it from being turned over to the Trustee. Unfortunately, shortly after receiving his discharge, the Debtor’s father died. Under the Bankruptcy Code, any non-exempt amounts payable to the Debtor under his father’s estate becomes property of the Chapter 7 estate. As his large refund was offset against priority tax debt by the IRS, the Debtor sought to re-allocate his exemptions to amounts payable under his father estate. The Trustee objected to this endeavor. We argued that a refund issued in the face of prior tax debt isn’t actually an asset. That is, an overpayment doesn’t actually become a “refund” until the IRS deems it to be. Therefore, the refund was not an asset subject to turnover to the Trustee.
End Result: This argument proved beneficial as we were able to settle with the Trustee to give the Debtor a larger exemption in amounts payable from his father’s estate, enabling him to keep close to $10,000 from his father’s estate, when he was initially entitled to a much smaller portion.
NYS Voluntary Disclosure Matters
Legal Issue: Client failed to file Sales Tax returns
Referred by: CPA.
Services Performed: Represented small business making a voluntary disclosure of several years of non-filing and non-payment of sales tax returns.
End Result: Were able to assist in closing the matter with no penalties and resolving the matter with an Installment payment agreement allowing the business to become current with tax obligations without impacting the business’ ability to operate.
Payroll Tax Representation
Legal Issue: Client failed to remit Payroll Taxes
Referred by: CPA
Services Performed: Represented foreign entity with a US presence. The entity worked with a payroll service to meet its US payroll requirements. The payroll service stopped filing and making the payroll tax payments, without the knowledge of the proper representative of the client. We represented the client before IRS collections and IRS Appeals with respect to the resulting penalties for the late filing and payment.
End Result: Argued for and received full abatement at IRS Appeals of approximately $120,000 of payroll tax penalty assessments.
Legal Issue: Create an estate plan that would distribute client assets in a specific way, and protect assets to the greatest extent possible.
Referred by: Financial Advisor
Services Performed: Designed and implemented a unique estate plan that achieved client goals. Working directly with the client’s financial advisor, we helped to diversify investments without paying unnecessary taxes and penalties, and assigned beneficiaries such that they would pass by operation of law, avoiding unnecessary probate costs and delays. We also drafted parallel Charitable Remainder Unitrusts enabling the protection of a large portion of the assets from potential creditors and Medicaid.
End Result: Our team was able to provide the client with a unique, custom estate plan that not only accomplished all dispositive goals, but also saved close to $100,000 while safely protecting assets going forward. We were also able to accommodate our referral partner by facilitating a transfer of assets from an annuity earning a small annual yield to a diversified investment account managed by the referring financial advisor while avoiding the taxes normally generated by that type of asset maneuver.
Prior results do not guarantee a similar outcome.