Experience

IRS Notice Contested for Online Payments Client

Successfully contested a notice of deficiency from the Internal Revenue Service for an online payments provider. The notice stated the client owed taxes and penalties in excess of $1 million.

Because the client often holds money in escrow for its clients and then disburses the funds, the IRS misinterpreted that money as actual income. We submitted a letter to the IRS notifying them of their error and began preparing a Tax Court petition. In the end, the IRS responded and ultimately closed the case with no additional tax liability.

Lead Counsel to Payments Processing Company

Lead counsel on successive transactions wherein client was deploying existing technology in innovative arrangements and new service lines with key business partners.