Case Results
Every case tells a story. See how our expertise in tax law has helped clients overcome financial and regulatory hurdles.
NCA Argyle LP v. Commissioner, T.C. Memo 2020-56 (2020). The IRS sought over $5 million in tax, penalty, and interest. In a complete taxpayer victory, the Tax Court held that a $23 million lump-sum payment of settlement proceeds to resolve a joint venture dispute between two partners resulted in capital gains and not ordinary income.
Medtronic, Inc. v. Commissioner, T.C. Memo. 2022-84 (2022). One of the most significant Section 482 transfer pricing disputes ever litigated in the Tax Court. The case involved a second trial in the U.S. Tax Court following the Eighth Circuit’s review and remand. The court’s 2022 opinion adopted Medtronic’s transfer pricing methodology but made certain adjustments in favor of the IRS.
Entered representation of film producer client during IRS audit that was not proceeding efficiently. Successfully engineered a resolution resulting in substantial tax savings and no imposition of proposed penalty of over $240,000.
Client Results
Helping clients navigate complex tax challenges isn’t just our job—it’s our commitment.
When, unbeknownst to us, our tax return preparer neglected to file our tax return on time, the IRS asserted a penalty of over $25,000. After other professionals were unsuccessful, I approached Drew to see if there was any more that could be done. Within a few months, Drew had the penalty abated and we received a full refund.
B and K, Menlo Park, CA
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