Tax Controversy
Contact from a federal or state tax agency can be concerning and stressful for a taxpayer. Cendrowski Corporate Advisors is committed to assisting its clients in preventing, managing, and settling controversies and conflicts. The firm acts efficiently to resolve outstanding disputes by coordinating the efforts of the client’s internal team and professional advisors at each step of the resolution process. We have established an excellent reputation within the IRS and various state authorities as resolute advocates for our clients in matters of tax controversy, both civil and criminal.
Example Engagement: Earned Income Tax Credits
We were requested to assist an attorney with a motion for summary judgement for his client. The clients’ disability payments were an issue due to income from his pizza business, held in an S corporation, being challenged as disqualifying income.
We researched and analyzed tax law, case law and applicable rulings to find support for concluding that the S corporation income from the pizza business, flowing through to the shareholder, was not “earned income” of the shareholder as a matter of fact under the law. We developed support from certain areas of tax law, i.e. the self-employment tax act along with laws governing retirement plans. We also provided the attorney with support and a defense analysis for certain other issues that could arise with an S corporation and characterization of income that may be challenged as disqualifying income for these purposes. Based on our analysis of the law and support, the attorney was successful in making a motion for summary judgement, which was granted in favor of his client and thereby, the client was able to continue receiving disability payments.
