04.01.11
Posted in Litigation, Taxation Law at 12:08 by Administrator
Q. My spouse and I are experiencing financial difficulties. Unfortunately, I suspect we may be headed for divorce. My spouse controls all the finances and I am concerned that mortgage or other payments might not continue to be made in a timely manner, out of spite, after we separate and begin the divorce process. How can the law protect me from this possibility?
A. It is not unusual for marital difficulties to be preceded by financial difficulties. It also is not uncommon for one spouse to take more responsibility for financial matters than does the other spouse. Ideally, spouses should be able to effectively communicate with each other and agree on issues concerning the management of financial and other marital issues. But such is not always reality.
A decision to stop making mortgage payments is sometimes a sound financial decision, given a certain set of facts. Other times, that same decision, in addition to simply being foolish, creates potential legal liability.
Whether to stop making monthly payments on a home mortgage involves consideration of numerous issues, as well as the interplay between those issues. Some of the legal issues relate to state contract, property, and foreclosure law, as well as federal and state tax law. Other issues include credit ratings and potential adverse affect on current or prospective employment, especially government employment which may require a national security clearance or where personal finances may be the subject of pre-employment or post-employment screening or monitoring.
In addition to the foregoing, a California Court of Appeal recently reminded married couples that a spouse who manages marital assets owes the non-managing spouse a fiduciary duty to preserve those marital assets. In re: Marriage of Kochan, No. B215355, Second Appellate District, California Court of Appeal (March 9, 2011).
In Kochan, one of the spouses had exclusive temporary use, possession, and control of the family residence during the divorce proceedings, and failed to make mortgage payments notwithstanding the financial ability to have done so. The Court of Appeal upheld the trial court’s finding that the marital fiduciary duty to preserve community assets had been breached, and left it to the trial court to determine, on remand, whether that breach of duty had caused any actual damage.
The appellate court also upheld the trial court’s order requiring the spouse who breached the fiduciary duty to pay $120,000 of the other spouse’s attorney fees. (The breach of fiduciary duty was only one of several issues which were litigated.)
There are certain procedures which might be appropriate for your case and which may help prevent this problem before it occurs, or at least minimize the possibility of it occurring. Thus, it is important that – at the outset of your case – you consult an attorney knowledgeable in family law matters.
This article is published in both print and electronic formats. You may register at http://earlelaw.com/newsletters to begin receiving future articles via a free email subscription to the EarleLaw Newsletter.
Earle Law Offices offers the LAW (Lawyer Available Whenever) Plan, which provides a cost-effective means of obtaining legal advice when such advice is most-needed: before a legal problem arises, or as soon thereafter as possible. For details, please visit: http://earlelaw.com/lawplan.html.http://earlelaw.com/lawplan.html.
*Anthony F. Earle, Esquire is a California attorney and real estate broker who maintains a practice in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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03.24.11
Posted in Litigation, Taxation Law at 12:31 by Administrator
Q. I recently was audited by the Internal Revenue Service (IRS), which now claims I owe additional income taxes. I disagree and am considering a challenge in Tax Court to this determination. If I win at Tax Court, is it possible to also obtain a court order requiring the IRS to pay some or all of my attorney fees? May I recover attorney fees even is someone else pays the fees for me?
” ‘[A] party who chooses to litigate an issue against the Government is not only representing his or her own vested interest, but is also refining and formulating public policy.’ INS v. Jean, 496 U.S. 154, 165 n. 14 (quoting H.R. Rep. No. 96-1418, at 10 (1980). For this reason, our legal system has adapted to ensure that, in certain circumstances, every citizen is able to defend himself against unjustified government action, free from the financial disincentives associated with litigation. [26 U.S.C. § 7430] provides such assurance to taxpayers.” Morrison v. Commissioner of Internal Revenue, 2009 WL 1312855 (C.A.9).
“The U.S. Tax Code permits a discretionary award of litigation costs, including attorneys’ fees, to the prevailing party in any civil tax proceeding brought by or against the United States. 26 U.S .C. § 7430(a). A ‘prevailing party’ is a party that ‘has substantially prevailed with respect to the amount in controversy’ or ‘with respect to the most significant issue or set of issues presented.’ § 7430(c)(4)(A)(i).” Id.
Section 7430 reads, in relevant part: “In any administrative or court proceeding which is brought by or against the United States in connection with the determination, collection, or refund of any tax, interest, or penalty under this title, the prevailing party may be awarded a judgment or a settlement for . . . reasonable litigation costs incurred in connection with such court proceeding.”
The issue in Morrison was whether a taxpayer may recover attorney fees after successfully challenging an IRS audit where a third party, instead of the taxpayer, advanced the taxpayer’s attorney fees to litigate against the IRS.
The fee controversy in Morrison arose after Morrison, a shareholder and officer in Caspian, a corporation, sold his interest in Caspian to Nariman Teymourian, another Caspian shareholder. Before Morrison resigned as an officer of Caspian, the IRS initiated audits of Morrison, Caspian, and Teymourian.
The IRS issued Notices of Deficiency to Morrison, Caspian and Teymourian. Morrison and Caspian each petitioned the United States Tax Court for redetermination. The tax court cases were consolidated and both parties retained the same law firm to represent them. After Morrison and Caspian both prevailed on their Tax Court petitions, both filed section 7430 motions seeking an award of attorney fees.
The Tax Court denied Morrison’s fee request on the ground that Morrison had not actually paid or “incurred” such fees, as Caspian had advanced Morrison’s fees under an agreement requiring Morrison to reimburse Caspian in the event Morrison was successful in obtaining a fee order against the IRS.
The IRS argued that Morrison had not “incurred” any attorney fees within the meaning of section 7430, arguing that a contrary interpretation of the term “incurred” would give rise to the so-called “stand-in” litigant problem. A stand-in litigant is one who seeks an award of attorney fees and then passes those fees on to an ineligible litigant.
This article is published in both print and electronic formats. You may register at http://earlelaw.com/newsletters to begin receiving future articles via a free email subscription to the EarleLaw Newsletter.
Earle Law Offices offers the LAW (Lawyer Available Whenever) Plan, which provides a cost-effective means of obtaining legal advice when such advice is most-needed: before a legal problem arises, or as soon thereafter as possible. For details, please visit: http://earlelaw.com/lawplan.html.http://earlelaw.com/lawplan.html.
*Anthony F. Earle, Esquire is a California attorney and real estate broker who maintains a practice in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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01.13.11
Posted in Bankruptcy, Litigation, Real Estate Law, Taxation Law at 08:48 by Administrator
Q. I own a California home, but like many residential properties, the value of my home has declined so much that I now owe much more on it than what it is worth. I have two mortgages on this property, a “first” and a fairly sizable “second” loan. Fortunately, I have access to a modest amount of cash, which I could use as a down payment on a new home. I am considering the purchase of a new house to use as my principal residence, so I can take advantage of the current “buyers’ market” for residential housing. If I purchase a new home, I would consider converting my current home into a rental property. What are the possible legal issues associated with this strategy?
A. Your idea sounds like a good one. It is also an idea many homeowners in your situation are considering. However, there are at least three potential complications associated with the strategy you describe.
Because you are “upside down” with respect to your current home, that is, you owe more against that property than it currently is worth, chances are that the rent it will generate will not be sufficient to pay the mortgages. Thus, it is likely you will have a monthly loss associated with that property, a loss which you will have to cover from other income or assets.
This likelihood of negative cash flows creates the possibility of the first legal issue: eventual foreclosure.
Second, in the event of a foreclosure on your current California home/prospective rental property, you may or may not be exposed to a deficiency judgment with respect to the first loan. A deficiency judgment is a civil judgment for the difference between the amount owed on a property and the amount ultimately obtained for that property at a foreclosure sale.http://earlelaw.com/news_family.html.
Regardless of the status of your first loan, there is a significant likelihood that you may be subject to a deficiency judgment with respect to the second, or junior, loans on this property.
Any California deficiency judgment obtained against you will be valid for 10 years, and can be renewed for additional 10 year periods.
Furthermore, a deficiency judgment can be recorded as a lien against your new home, or against any other interest in real property which you may own, purchase, or acquire. Any lien recorded against a parcel of real property must, of course, be satisfied before that property can be sold.
Third, there are potential tax consequences, relating to the cancellation of debt, which might require that you pay income tax on any deficiency amount related to a foreclosure, even if a deficiency judgment is not obtained.
Whether you are a home/property owner who is in the undesirable position of deciding what to do with a distressed property, or a lender (institutional or private) who owns distressed loans, you would be well-advised to consult with an attorney before embarking on a course of action designed or intended to mitigate your monetary loss.
*Anthony F. Earle, Esquire is a California attorney and real estate broker who maintains a practice in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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12.30.10
Posted in Taxation Law, Trusts and Estates at 10:59 by Administrator
Q. My spouse and I have been procrastinating when it comes to regular reviews of our estate plan. Now, with another new year about to being, and a new tax law just around the corner, we would like to know whether there is any compelling reason to have an attorney review our estate plan now.
A. The Middle Class Tax Relief Act of 2010 (”2010 Tax Act”) was enacted during December 2010. However, contrary to its name, the 2010 Tax Act does not offer much relief at all. In fact, in the area of estate taxation, tax rates increase from 0% in 2010 to 35% in 2011, on that portion of estates which exceed $5 million. But that is only the tip of the taxation iceberg.
Using the new $5 million estate tax exclusion, married couples can avoid estate taxes on the first $10 million of their combined estates. If the first spouse to die does not fully use his or her exclusion, the unused portion can be used by the surviving spouse. However, with an A-B Trust – a type of trust which commonly was used prior to 2011 – the transferability of all or part of a deceased spouse’s $5 million exclusion may cause problems which reasonably could not have been anticipated when the A-B Trust was created.
The problem arises in the interplay between the “unlimited marital deduction” (”UMD”), on the one hand, and the $5 million exclusion which was created by the 2010 Tax Act, on the other hand. Many existing estate plans were drafted with an eye toward taking advantage of the UMD, without, of course, any consideration of the newly-enacted 2010 Tax Act.
In most cases, the UMD provides that, regardless of the size of an estate, there are no estate taxes on the first death. Because A-B Trusts typically were drafted to take advantage of the UMD, and did not transfer assets to take advantage of an exclusion that did not exist prior to 2011, continued use of an A-B Trust may result in married couples being subject to estate taxes on that portion of their estate which exceeds $5 million, rather than on full $10 million exclusion that they should be able to enjoy.
Thus, beginning on January 1, 2011, A-B Trusts will be obsolete. Accordingly, most, if not all, A-B Trusts should be reviewed and revised to take advantage of the new $5 million exclusion.
Now, as Paul Harvey might have said, here is the rest of the story: A-B Trusts, in order to take advantage of the UMD, intentionally waived a step-up in basis to avoid estate taxes because, with the exception of 2010, estate tax rates have always been significantly higher than capital gains tax rates. Now, however, use of an A-B Trust may expose the estate of all married couples – regardless of the value of the estate – to a loss of their step-up in basis which, in turn will increase their exposure to capital gains tax, while simultaneously doing nothing to protect against or mitigate estate taxation.
Estate plans should always be reviewed and updated any time there is either a change in the law or in your personal circumstances. So resolve now to put a review of your estate plan (or creation of an estate plan, if you do not already have one) at or toward the top of your 2011 list of “To Do” items.
*Anthony F. Earle, Esquire is a California attorney and real estate broker who maintains a practice in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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12.17.10
Posted in Real Estate Law, Taxation Law at 18:43 by Administrator
Q. My spouse and I are interested in buying our first home. Considering the current downturn in the economy in general and the real estate market in particular, what should we consider when purchasing a residence?
A. Depreciation in the value of residential real property, combined with mortgage interest rates which currently are at near historic lows, make this an excellent time to purchase real estate.
For example, a recent search of multiple listing service (MLS) listings for single family residences (SFRs) in the Silicon Valley area of northern California revealed that a 3-bedroom, 2-bath home (3/2) can be purchased for $750,000. The MLS also contains listings for 3/2 SFRs starting at about $500,000 and exceeding $1 million.
If one were to make a ten percent down payment on a $750,000 SFR, a loan for the balance would be needed in the amount of 675,000. Assuming a 30 year loan with an interest rate of 5%, monthly payments of principal and interest would be approximately $3,624. Interest on the mortgage would be deductible for income tax purposes (IRS Publication 936, Home Mortgage Interest Deduction), unless the mortgage interest deduction (MID) is removed from the tax code, as has recently been discussed in Congress.
Another recent search of MLS listings for the Silicon Valley area revealed that a four-unit residential property can be purchased for $1 million. Less expensive and, of course, more expensive four-unit complexes are also available.
Assuming a ten percent down payment, a loan of $900,000 would be needed to purchase a $1 million fourplex. Monthly principal and interest payments on a 30 year loan with an interest rate of 5% would be approximately $4,831. Interest attributable to units which are rented to tenants would be deductible for tax purposes as a business expense. See, Chapter 4, IRS Publication 535 (Business Expenses) and IRS Publication 527 (Residential Rental Property).
Assuming a fair market rental value of $1,200 per month for each unit, and a ten percent vacancy rate, rental income generated by three of the four units should be $3,240 per month. If you and your spouse used the fourth unit as your residence, your effective mortgage payment or “rent” would be $1,591 per month, which is $2,033 per month less than your mortgage payment would be if, as in the first example, you purchased a SFR.
You will, under each of the above examples, incur expenses for routine maintenance, property taxes, and insurance. These expenses will be mostly tax deductible if you own the fourplex, but mostly not tax deductible if you own the SFR. Additionally, if you own the fourplex, you will have an additional deduction for depreciation, a deduction which will not be available if you purchase the SFR.
Finally, when you and your spouse sell the fourplex, you should be able to take advantage of tax rules relating to “like-kind” exchanges, to defer capital gains tax. However, if you and your spouse purchase the SFR, the amount of capital gain which can be excluded from taxation may be limited.
The SFR will likely provide you and your spouse with a home that is more comfortable and aesthetically appealing than a fourplex, but becoming an owner of residential rental real estate should be a good first step on your road to financial prosperity and independence.
*Anthony F. Earle, Esquire is a California attorney and real estate broker who maintains a practice in the Silicon Valley area of northern California. He can be reached at: anthony.earle@earlelaw.com. This article is intended for information and educational purposes only, and is not intended to constitute legal advice.
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10.02.10
Posted in Real Estate Law, Taxation Law at 08:22 by Administrator
Q. I own several investment rental properties, several single family homes, a duplex, and a four-plex. Because there currently exist many good opportunities to purchase investment real estate, I am considering selling one or more of the investment properties which I currently own and using the proceeds from the sale to purchase additional investment properties. However, I am concerned about the tax consequences of selling properties which I now own. What should I know about capital gains tax?
A. Real estate investors have various “tools” in their investment “toolboxes” which can be used to increase both the net value and diversity of a real estate portfolio. One powerful “tool” is the Like-Kind Exchange, also known as Section 1031 of the Internal Revenue Code or the “1031 Exchange”.
Tax obligations are a major obstacle to the creation and retention of wealth, as most real estate transactions have tax consequences. The Internal Revenue Code (IRC) requires a taxpayer to pay tax on a real estate transaction where the fair market value (FMV) of property received (e.g., cash) is greater than the adjusted basis of a property given up (i.e., investment real property). In other words, if a real estate investor sells an investment property for an amount greater than its adjusted basis, the difference between the sale price of the property and the property’s adjusted basis will be subject to capital gains tax. (The “basis” of an asset is generally its cost. However, basis may be adjusted over the course of time due to various events. The basis of property must be increased by capital expenditures and decreased by capital returns. Increases in basis have the effect of reducing the amount of gain realized or increasing the amount of realized loss. Decreases in basis have the effect of increasing the amount of realized gain or decreasing the amount of loss.)
Although the general rule is that a real estate investor must recognize a capital gain on the sale of investment real property where the FMV of the property sold is greater than the property’s adjusted basis, IRC section 1031 provides taxpayers with a mechanism to defer recognition of the gain to the extent that the investment property which is given up is exchanged for a property of “like-kind”.
Like-kind property is alike in nature or character, but not necessarily in grade or quality. Real property is of like-kind to all other real property, except for foreign real property. Examples include single family residence for apartment building, or commercial building for parking lot. A lease of real property for 30 or more years is treated as real property.
“Boot” is all property which does not qualify for Section 1031 treatment. Boot includes cash received, net liability (e.g., mortgage) relief, and the FMV of other non-qualified property received.
The basis in property acquired in a like-kind exchange is equal to: adjusted basis of property given + gain recognized + boot given (cash, liability incurred, other property) – boot received (cash, liability relief, other property).
An exchange of like-kind properties must be completed within the earlier of 180 days after the transfer of the exchanged property or the due date (including extensions) of the transferor’s tax return for the taxable year in which the exchange occurred. Also, the replacement property must be identified as such not later than 45 days after the date on which the transferor transfers the property. The identification of multiple replacement properties is permitted. Special rules apply to exchanges between “related” parties.
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04.24.10
Posted in Real Estate Law, Taxation Law at 09:56 by Administrator
Under federal tax law, all income is subject to taxation, unless specifically exempted. Debt which a lender forgives or cancels – commonly referred to as cancellation of debt (COD) income – is considered to be income to the borrower and, thus, generally is subject to federal taxation. Current federal law provides for a temporary exemption for taxation of COD.
On April 13, 2010, California enacted state Senate Bill 401, which brings California state law concerning COD income substantially in accord with current federal law. Pursuant to SB 401, distressed homeowners will no longer have to pay California state income tax on debt forgiven in a short sale, foreclosure, or loan modification. For debt forgiven on a loan secured by a “qualified principal residence,” borrowers will now be exempt from both federal and state income tax consequences. The existing federal exemption is for indebtedness up to $2 million, whereas the new California exemption is for indebtedness up to $800,000 and forgiven debt up to $500,000.
“Qualified principal residence” indebtedness is defined as debt incurred in acquiring, constructing, or substantially improving a principal residence. It includes both first and second trust deeds. It also includes a refinance loan to the extent the funds were used to payoff a previous loan that would have qualified.
The California exemption applies to debts discharged from 2009 through 2012. Californians who have already filed their 2009 tax returns may claim the exemption by filing a Form 540X amendment.
Taxpayers who do not qualify for the above exemptions (e.g., second home or rental property) may nevertheless be exempt under other provisions. Most notably, taxpayers who are bankrupt are exempt from debt relief income tax. Also, taxpayers who are insolvent are exempt from debt relief income tax to the extent their current liabilities exceed current assets.
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02.06.10
Posted in Taxation Law at 08:36 by Administrator
Taxpayers who need their past tax return information can obtain it from the IRS. Here are eight things to know if you need copies of your federal tax return information.
1. There are two easy and convenient options for obtaining free copies of your federal tax return information – tax return transcripts and tax account transcripts.
2. The IRS does not charge a fee for transcripts, which are available for the current year as well as the past three years.
3. A tax return transcript shows most line items from your tax return as it was originally filed, including any accompanying forms and schedules. It does not reflect any changes you, your representative or the IRS made after the return was filed. In many cases, a return transcript will meet the requirements of lending institutions, such as those offering mortgages and student loans.
4. A tax account transcript shows any later adjustments either you or the IRS made after the tax return was filed. This transcript shows basic data – including marital status, type of return filed, adjusted gross income and taxable income.
5. To request either transcript by phone, call 800-829-1040 and follow the prompts in the recorded message.
6. To request a tax return transcript through the mail, individual taxpayers should complete IRS Form 4506T-EZ, Short Form Request for Individual Tax Return Transcript. Form 4506T-EZ is only for individuals who filed a Form 1040 series return. Businesses, partnerships and individuals who need transcript information from other forms or need a tax account transcript must use the Form 4506T, Request for Transcript of Tax Return.
7. You should receive your tax return transcript within 10 working days from the time the IRS receives your request. Allow 30 calendar days for delivery of a tax account transcript.
8. If you still need an actual copy of a previously processed tax return, it will cost $57 per tax year and take much longer. Complete Form 4506, Request for Copy of Tax Form, and mail it to the IRS address listed on the form for your area. Please allow 60 days for actual copies of your return. Copies are generally available for the current year as well as the past six years.
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Special Offer
Representation by an attorney is included in the fee for every federal and California state tax return prepared by Earle Law Offices (subject to certain conditions, limitations, and restrictions). Attorney representation of taxpayer clients includes representation at audit, administrative appeal, and in civil litigation.
Tax controversy services are also available in cases where the disputed return was prepared by the taxpayer or a third party.
Further information on tax preparation and tax controversy services offered by Earle Law Offices is available at: www.EarleLaw.com/tax.
Please call Earle Law Offices today to schedule an appointment to have your 2009 tax returns prepared.
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01.20.10
Posted in Taxation Law at 20:24 by Administrator
If you were married or divorced recently, there are a couple of things you’ll want to do to ensure the name on your tax return matches the name registered with the Social Security Administration (SSA).
Here are five facts from the IRS for recently married or divorced taxpayers. Following these steps will help avoid problems when you file your tax return.
If you took your spouse’s last name or if both spouses hyphenate their last names, you may run into complications if you don’t notify the SSA. When newlyweds file a tax return using their new last names, IRS computers can’t match the new name with their Social Security Number.
If you were recently divorced and changed back to your previous last name, you’ll also need to notify the SSA of this name change.
Informing the SSA of a name change is a snap; you’ll just need to file a Form SS-5, Application for a Social Security Card at your local SSA office.
Form SS-5 is available on SSA’s Web site at www.socialsecurity.gov, by calling 800-772-1213 or at local offices. It usually takes about two weeks to have the change verified.
If you adopted your spouse’s children after getting married, you’ll want to make sure the children have an SSN. Taxpayers must provide an SSN for each dependent claimed on a tax return. For adopted children without SSNs, the parents can apply for an Adoption Taxpayer Identification Number – or ATIN – by filing Form W-7A, Application for Taxpayer Identification Number for Pending U.S. Adoptions with the IRS. The ATIN is a temporary number used in place of an SSN on the tax return. The W-7A is available on IRS.gov, or by calling 800-TAX-FORM (800-829-3676).
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Special Offer
Representation by an attorney is included in the fee for every federal and California state tax return prepared by Earle Law Offices (Subject to certain conditions, limitations, and restrictions). Attorney representation of taxpayer clients includes representation at audit, administrative appeal, and in civil litigation.
Tax controversy services are also available in cases where the disputed return was prepared by the taxpayer or a third party.
Further information on tax preparation and tax controversy services offered by Earle Law Offices is available at: www.EarleLaw.com/tax.
Please call Earle Law Offices today to schedule an appointment to have your 2009 tax returns prepared.
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01.15.10
Posted in Taxation Law at 19:43 by Administrator
It is important to exercise due diligence when selecting and retaining a tax professional. Remember, you are legally responsible for what’s on your tax return even if it was prepared by an another person or firm.
Most tax return preparers are professional, honest and provide excellent service to their clients. However, unscrupulous tax return preparers do exist and can cause considerable financial and legal problems for their clients. Therefore, it’s important to find a qualified tax professional.
The following tips will help you choose a preparer who will offer the best service for your tax preparation needs.
1. Check qualifications. Ask if the preparer is affiliated with a professional organization that provides its members with continuing education and resources and holds them to a code of ethics.
2. Check professional record. Check to see if the preparer has any questionable history with the licensing authorities such as the IRS, the state’s board of accountancy for CPAs, or the state’s bar association for attorneys.
3. Ask about fees. Avoid preparers that base their fee on a percentage of the amount of your refund or those who claim they can obtain larger refunds than other preparers.
4. Determine accessibility. Make sure you will be able to contact the tax preparer after the return has been filed, even after April 15, in case questions arise.
5. Provide all records and receipts. Most reputable preparers will ask to see your records and receipts and will ask you multiple questions to determine your total income and your qualifications for expenses, deductions and other items.
6. Never sign a blank return. Avoid tax preparers that ask you to sign a blank tax form.
7. Review your return before signing it. Before you sign your tax return, review it and ask questions. Make sure you understand everything and are comfortable with the accuracy of the return before you sign it.
8. Make sure the preparer signs your return. A paid preparer must sign the return as required by law. Although the preparer signs the return, you are responsible for the accuracy of every item on your return. The preparer must also give you a copy of the return.
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Special Offer
Representation by an attorney is included in the fee for every federal and California state tax return prepared by Earle Law Offices (Subject to certain conditions, limitations, and restrictions). Attorney representation of taxpayer clients includes representation at audit, administrative appeal, and in civil litigation.
Tax controversy services are also available in cases where the disputed return was prepared by the taxpayer or a third party.
Further information on tax preparation and tax controversy services offered by Earle Law Offices is available at: www.EarleLaw.com/tax.
Please call Earle Law Offices today to schedule an appointment to have your 2009 tax returns prepared.
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