Robison Law Firm

Your client's financial success does not result from a single action or strategy. Rather it is achieved over time, following plans carefully thought out over a period of years. Clients today look for an edge. Your guidance is crucial to their success. Specialized knowledge regarding federal tax law can give you and your clients that edge.

You need tax and business attorneys who can provide timely, innovative and creative tax and business solutions that increase cash flow, reduce, defer or eliminate taxes, and retain equity and increase wealth. They should be actively involved from initial planning, tax opinions, private letter rulings, tax elections, change in methods to reviewing or amending tax returns, penalty abatement, mitigation and claim of right, representing on audits and appeals to negotiating settlements and collection issues as well as U.S. Tax Court. This helps eliminate risk and taxes.

Look for the following value-added services:

1. Business Planning
   a) Initial structure, creating the right entity and tax interaction
   b) Ongoing operations, using the tax code to improve efficiency
   c) Succession Planning, either transfer or sale
2. Tax Planning
   a) Increasing wealth, using the tax code to reduce taxes
   b) Efficiently investing wealth
   c) Transferring wealth, structuring to work now and into the future
3. IRS Representation
   a) 9100 Relief, change of methods and elections
   b) Examination and Appeals
   c) Relief from tax collection
   d) Tax court
4. Specialized Services
   a) Tax opinions and/or Private Letter Rulings
   b) Innocent Spouse Relief proceedings
   c) International Tax issues
5. Your Tax Partner™, providing risk management for you, and for your clients

Contact the Robison Law Firm and let us help you with your tax and business planning needs.

Focused Examples of Robison Law Services

EXAMPLE #1: Client sold its business, distributed out all assets except the defined benefit retirement plan assets. However, under federal tax law at the time, the plan was considered overfunded, which resulted in over $800,000 in excise taxes and penalties. RLF's team of tax lawyers designed a specialized investment product based on federal tax law to permit the distribution to an IRA saving client $ 760,000 in excise taxes overfunding liability.

EXAMPLE #2: A grain export company was under IRS Examination based on proposed accounting method and timing issues relative to its purchase and delivery of grain, with agent proposing over $250,000 in additional taxes and penalties. RLF was retained and using tax and accounting research, including permitted structural business changes, along with an IC-DISC election, obtained a refund of nearly $150,000 at the conclusion of the IRS audit and permanently avoided the impact of the uniform capitalization rules.

EXAMPLE #3: Due to deteriorating market conditions, a real estate partnership faced a potential multi-million dollar capital loss on the sale of its sole asset, unimproved land. The U.S. and UK partners were high income consultants but did not own any appreciated capital assets to offset the capital loss. Capital losses can be absorbed against U.S. source income to the extent of $3,000 per year, which would stretch long past their expected lifetime. RLF's tax lawyers designed a strategy to convert the nature of the underlying asset, permitting its disposition as a Section 1231 ordinary loss, which offset their ordinary income, saving approximately $4,000,000 in income taxes.

EXAMPLE #4: Client discovered that they would have benefited by electing Section 338(h)(10) for a transaction in a prior year. Even though the statute for making the election had long expired, the RLF team prepared a Section 9100 Relief which entitled the client to retroactively make the election.

EXAMPLE #5: Client was awarded a large bonus from a Family business. Unknown to the Client, the owner of the business was involved in an elaborate scheme to defraud other parties. All members of the family received prison sentences. The monies received in the prior years were seized by the government, including the Client's home and other assets. The RLF team was engaged to represent the Client and successfully utilized the mitigation provisions to refund the incomes taxes paid on the seized assets, allowing the Client to restart their lives anew.