Darshan Patel (Associate-Madison, NJ) defended an entity in the hotel industry facing tax penalties in the amount of $578,000 under Internal Revenue Code sections 6721 (failure to file correct information returns) and 6722 (failure to furnish payee statements or required information). These failures were out of the client’s control at the time but resulted in penalization by the IRS.

Over the course of almost two years, using Treasury regulations, and eventually having the IRS Advocates Office support the client’s position, Darshan and the Tax Planning & Controversies team successfully persuaded the IRS to abate 100 percent of the client’s tax penalties and avoided having to litigate the matter in court. This is a remarkable turnaround with notable and meaningful financial results for the client.