Tax Planning and Controversy Resolution

The lawyers of Sullivan McGregor & Doerr LLP have, among them, decades of experience in tax planning. Our primary goal is to minimize the client’s tax exposure in a way that both achieves the client’s goals and minimizes the risk of an adverse determination should the plan be audited by the authorities. We counsel clients on a wide range of income, estate, employment, property, and sales and use tax matters.

Our approach to tax planning is largely shaped by our substantial experience in resolving tax controversies. Our lawyers have successfully resolved the following reported income and estate tax cases:

Estate of Frazier v. Commissioner (9th Cir. 2003) 2003-2 USTC 60,473 reversing and remanding TC Memo 2002-120, and (9th Cir. 2001) 2001-1 USTC 60,404, reversing and remanding TC Memo 1999-201 [buildings and roads built at the tenant’s cost on leased property were not includable in the landlord’s estate for estate tax purposes despite their permanent nature].

Salwasser v. Commissioner, TC Memo 1991-466 [amounts paid to organization implicated in Iran-Contra scandal held deductible as charitable contributions].

Dorothy Schwartz Rojas v. Commissioner (1988) 90 TC 1090, affirmed, (9th Cir. 1990) 901 F2d 801 [on liquidation of a corporation, the tax benefit rule did not require the corporation’s shareholders to include in income its expenses of farming a crop that was unharvested at the time of liquidation].

Giannini Packing Corp. v. Commissioner (1984) 83 TC 526 [agricultural cold storage facility held eligible for the investment tax credit].

Zaninovich v. Commissioner (9th Cir. 1980) 616 F2d 429, reversing (1978) 69 TC 605 [cash basis farmer’s payment of farm rental attributable to following tax year held deductible in the year paid].