We Listen Carefully
Your priorities are our priorities. We want to understand you so that we can deliver what matters most to you. Some people value speedy resolution to tax issues even if that requires significant compromise, while others desire absolute victory at any cost. Most people fall somewhere in between. Some people tolerate risk well, while others feel tortured by it. For many, the immediate tax conflict we are handling is part of a much bigger picture that we need to understand in order to give meaningful guidance. Our first priority is to listen and learn what matters to you so that we can tailor our strategy to achieve your unique goals.
We Think Creatively
We do not use auto-pilot to set or to follow a typical course. We employ our experience and creativity to develop a strategy that is most likely to achieve your unique goals. We think before we act, and then we think again and again throughout the handling of a tax matter to make sure that we are following the best course for you. When we hit a roadblock, we analyze all the different ways to go over it, under it, or around it instead of simply continuing to drive into it.
We Advocate Powerfully
Different situations call for different types of tax advocacy, and we know when and whether to draw each weapon from our arsenal. Whether we are persuading a revenue agent to take a favorable position on audit, negotiating with an appeals officer, cross-examining a witness at trial, drafting briefs, or arguing to a three judge panel on appeal, we have the experience and the skills to advocate effectively in a way that is tailored to the audience.
We Communicate Effectively
We give honest feedback and guidance in a way you can understand without ever causing you to question whether we are on your side. We don’t simply give you a list of pros and cons, we help you choose the right path forward. We explain what we are doing and why, we keep you informed of deadlines, and we tailor our methods of communicating with you to meet your preferences. We also work well as part of a team with other advisors you may already have, and can scale our role on your team up or down depending on your needs.
We Work Efficiently
We have worked closely together for so long that we know which one of our team members is most well-suited to any given task and how to divide the workload in a way that eliminates duplication of effort while maximizing results. We also have systems in place that allow us to manage information and tasks electronically so any member of our team can easily see where a project stands, what needs to be done next, and who is responsible for taking that next step.
Jenny L. Johnson and Guinevere M. Moore prevailed after trial and briefing in case where the IRS asserted transferee liability against a former shareholder of a family business as a result of the taxpayers’ alleged participation in a Midco intermediary tax shelter transaction. On December 1, 2015, the United States Tax Court issued an opinion in favor of the taxpayers in John M. Alterman Trust, Transferee v. Commissioner, T.C. Memo, 2015-231. Judge Ronald Buch found that the Commissioner failed to meet his burden of proving fraudulent transfers due to evidentiary holes in the record. The opinion is available here.
On January 29, 2016, Jenny L. Johnson presented at the ABA Tax Section 2016 Midyear Meeting in Los Angeles, California, leading a panel discussion with the Honorable Michael B. Thornton, Chief Judge of the United States Tax Court, the Honorable Lewis R. Carluzzo, Special Trial Judge of the United States Tax Court, and Peter K. Reilly, Special Counsel of the Internal Revenue Service. The panel explained how to construct decision documents that accurately reflect the terms of the resolution of a case and explored the options available to a taxpayer if the IRS fails to implement the decision in the manner the taxpayer anticipated or charges more interest than the taxpayer believes is correct.