IRS & California Tax Case Results

The results below reflect real outcomes Kugelman Law has secured for clients in federal and California tax matters, ranging from IRS audits and collections to U.S. Tax Court litigation and cryptocurrency tax controversies.

Our team is led by founder and managing attorney Alex Kugelman, who has nearly two decades of federal tax controversy experience and has been quoted in the Financial Times and the New York Post on California’s residency audits of departed wealthy residents. The team also includes former IRS Revenue Agent Otto Bosch, quoted in Tax Notes on IRS examination training and audit campaigns.

Every matter turns on its own facts; the summaries below describe what we achieved for specific clients.

U.S. Tax Court Litigation & Appeals

U.S. Tax Court Settlement: Over $1.2 Million in IRS & California Tax Exposure Resolved

A client came to Kugelman Law facing two IRS Notices of Deficiency proposing more than $557,000 in federal tax and penalties across six years, with substantial interest accruing and corresponding California tax exposure looming.

We took the matter to U.S. Tax Court and negotiated a settlement that eliminated the tax and penalties entirely for three of the six years and significantly reduced the rest, cutting the federal liability to roughly $38,000. Between the reduced tax and penalties, avoided interest, and the California exposure that never materialized, the result saved the client more than $1.2 million.

IRS Appeals Concession: $130,000 Eliminated with Zero Tax, Penalties, or Interest

A client challenging a proposed IRS liability received a full concession from IRS Appeals. We successfully contested the liability, saving the client $130,000 and ensuring the final court decision reflected no tax, penalties, or interest due. The client described the outcome as the work of “an absolute magician.” Learn more about our U.S. Tax Court litigation work.

IRS Audits

Audit Reconsideration: $400,000 CP2000 Assessment Removed

Through an audit reconsideration, we had an audit assessment of more than $400,000 removed from a CP2000 notice, saving the client a substantial amount and bringing the tax issue to a close.

Tax Collections & Penalties

Trust Fund Recovery Penalty: $150,000 in Personal Liability Removed

A client faced a Trust Fund Recovery Penalty determination that imposed $150,000 in personal liability. Our team appealed the determination and secured its complete removal, providing significant relief. See how we handle tax collections matters.

IRS Tax Debt: $365,000 Reduced to $0

A client came to Kugelman Law with a significant IRS debt of $365,000 resulting from past TurboTax mistakes. Through our team’s efforts, we brought the client’s balance down to zero. Explore our IRS representation and tax relief services.

Tax Relief & Refunds

Amended Return: $157,000 in Tax, Penalties, and Interest Eliminated, Plus a Refund

A client faced an IRS balance of more than $157,000 in back taxes, plus accrued penalties and interest. After a thorough review, we determined that an amended return was the best path to correct the underlying liability. The IRS not only removed the entire $157,000 balance but issued the client a refund. Learn more about tax relief and IRS representation.

Frequently Asked Questions About Tax Case Results

Can the IRS reduce a tax debt to zero?

Yes, in the right circumstances. Depending on the facts, a liability can be reduced or eliminated through audit reconsideration, an amended return, an appeal, a U.S. Tax Court challenge, or a collection alternative. Outcomes depend entirely on the specific facts of each case.

What is audit reconsideration?

Audit reconsideration is an IRS process for reevaluating the results of a prior audit or a CP2000 notice when a taxpayer has new information or believes the assessment is incorrect. It can result in an assessment being reduced or fully removed.

What is the Trust Fund Recovery Penalty, and can it be removed?

The Trust Fund Recovery Penalty allows the IRS to hold individuals, such as business owners or officers, personally liable for a company’s unpaid payroll taxes. A determination can sometimes be appealed and removed where the individual was not a responsible person or did not willfully fail to pay.

How are U.S. Tax Court cases resolved?

Many U.S. Tax Court cases settle before trial. A settlement can eliminate or substantially reduce the tax and penalties the IRS originally proposed, and it is then reflected in a stipulated decision and a final tax computation.

Do these results guarantee a similar outcome for my case?

No. Every tax matter turns on its own facts, and past results are not a guarantee of future outcomes. To discuss your situation, call (415) 968-1780 to schedule a paid, privileged consultation.

Speak With a California Tax Attorney

If you are facing an IRS or California tax matter, Kugelman Law offers paid, privileged consultations that are fully protected by attorney-client privilege. Call (415) 968-1780 or contact us to schedule yours.

Past results are not guaranteed and differ on a case-by-case basis. Results depend on specific facts, and past results do not guarantee future outcomes.