Represented clients in Tax Court matter involving the proper determination of capital gain pursuant to an installment contract for the sale of a commercial real estate property under section 453, and separately, whether the clients were entitled to exclude $500,000 of capital gain from the sale of their primary residence pursuant to section 121. Filed pretrial motion challenging the imposition of over $150,000 in penalties which led the IRS to concede the penalty in its entirety without even submitting an opposition brief to the Court. Subsequently reached a favorable settlement saving the clients over $700,000 in tax and interest, for a total savings of over $850,000.
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