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Representative Matters

Below is a small, representative sampling of cases I am working on or have completed in the recent past:

Represented a professional in an IRS criminal investigation lasting over two years. The investigation was subsequently dropped.

Represented a tax return preparer under criminal investigation by the IRS. The investigation was subsequently dropped.

Represented a professional in a New York State criminal tax investigation which was subsequently dropped and transferred to the civil division.

Drafted and filed a brief in a recent residency case before the New York Tax Appeals Tribunal. The case was subsequently settled.

Sued the IRS in federal district court for failing to turn over documents in a FOIA request. My request was subsequently satisfied in full with full reimbursement by the IRS for costs.

Represent individuals in the IRS Offshore Voluntary Disclosure Initiative. This program was extended in January 2012.

Represent many individuals and businesses in the New York State Department of Taxation and Finance's Voluntary Disclosure Program saving my clients hundreds of thousands of dollars in tax, interest and penalties.

Represent a corporation in a New York City Department of Finance Voluntary Disclosure.

Recently settled a case before the IRS for an individual who had not filed returns in over ten years. After filing all of the returns he owed over $325,000 of tax, interest and penalties. He settled with the IRS for approximately $10,000.

Represent a business professional in an IRS traditional voluntary disclosure for unfiled corporate, payroll and personal tax returns going back many years.

Obtained a favorable plea (no jail, no probation) for my client who was indicted for healthcare fraud by the New York County District Attorney's Office. My client's three business licenses were completely restored after rounds of hearings allowing my client to get on with providing for his family.

Represented an individual before the New York State Department of Taxation and Finance in a responsible officer case. The entire assessment was cancelled and the amounts levied from his brokerage account refunded in full.

Convinced an IRS Revenue Officer to drop a responsible person assessment against an elderly man by showing he had absolutely no involvement in his son's restaurant.

Obtained fair settlements with IRS Chief Counsel's office in docketed cases before the U.S. Tax Court for issues involving alimony deductions, rental real estate, penalty abatement and substitute for returns.

Obtained the cancellation of a $1 million dollar proposed assessment in a docketed U.S. Tax Court case by showing my client had basis in her stock sales and that the sale of her home qualified for the home sale exclusion. She had an overpayment of tax by the time I completed the case.

Obtained removal of a New York tax assessment by showing the tax was discharged in a 1990s bankruptcy.

Represent many clients before the Appeals Division of the IRS in collection and audit issues.

 

 


The Law Office of John J. Genova assists clients with tax problems throughout New York City including Manhattan, Queens, Brooklyn, Bronx and Staten Island.

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