Larry Jones
Tax Attorney
Experience You Can Trust


Townsend & Jones, LLP

Tax Attorney Larry Jones' Representative Cases

The focus of Mr. Jones is to attempt to resolve matters in the most economical manner at the lowest level of the IRS administrative process. This means trying to resolve IRS matters at the district level or the Appeals Office before filing suit against the IRS. Set forth below are representative cases handled by Mr. Jones:
  1. After audit the IRS issued a statutory notice of deficiency alleging that the taxpayers were liable for taxes and penalties totaling $10,528,232 plus interest. Successful negotiations with the IRS Appeals Office and District Counsel resulted in a full concession by the IRS.
  2. During audit the IRS proposed to disallow a loss for worthless stock. The total amount of the proposed assessment was $133,000 plus interest. Negotiations with the IRS Appeals Office resulted in an allowance of 70% of the stock loss in the year at issue and the carry forward of the balance to future years.
  3. The IRS proposed to treat certain workers of the taxpayer as employees and not independent contractors. The proposed assessment was $180,764 plus interest. Successful negotiations with the IRS Appeals Office resulted in a no change and continued treatment of the workers by the taxpayer as independent contractors.
  4. Upon audit the IRS determined the taxpayer’s farm was a hobby and no expenses were deductible. After a proposed assessment of $111,183 plus interest, the IRS Appeals Office conceded that the taxpayer was in the farming business and entitled to deduct all of the claimed expenses.
  5. After a criminal investigation and a lengthy audit, the IRS proposed substantial deficiencies against the taxpayers, including the fraud penalty. A settlement favorable to the taxpayers, including a concession of all penalties, was obtained after filing suit against the IRS.
  6. The IRS upon audit proposed additional income taxes against the taxpayers in the amount of $153,022 plus interest. The issues involved included a cancellation of debt issue and other issues involving losses. The IRS Appeals Office made a full concession after reviewing the taxpayers’ protest.
  7. The taxpayer had been assessed a trust fund recovery penalty in the amount of $94,684. By the time the taxpayer consulted Mr. Jones, the amount owed, including interest, was in excess of $100,000. An offer was made based on doubt as to liability. While the IRS District Office rejected the offer, the IRS Appeals Office settled the liability for $12,500.
  8. The taxpayer was assessed substantial penalties for failure to file Forms 5472 (Information Return of a Foreign Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business) pursuant to Section 6038A of the Internal Revenue Code. After filing suit against the United States, a settlement favorable to the taxpayer was reached.
  9. Upon audit the IRS proposed an assessment against the taxpayer in the amount of $57,842 plus interest. The issue involved was whether the taxpayer was entitled to deduct guarantee fees paid to its shareholders for them guaranteeing loans to the taxpayer. A successful Appeals Conference resulted in a full concession by the IRS.
  10. The IRS proposed a trust fund recovery penalty of $64,293 against the taxpayer. The proposed penalty was fully conceded by the Revenue Officer after a full presentation of the facts involved.
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