- Tax Court Trials
- Innocent Spouse Relief Trials
- Refund Claim (U.S. District Court) Trial
- Criminal Tax Trials
- Tax Fraud Trials
- Jury and Bench Trials
- Business Expense Substantiation Trials
- Omitted Income and Understated Income Trials
Notable IRS and California agency concessions achieved by Mr. Layton include:*
- Concession of over $1 million in tax, penalty, and interest in United States Tax Court.
- Waiver of Fraud Penalties in United States Tax Court.
- Concession of over $300,000 of taxes and release of tax liens against a recently divorce wife via Innocent Spouse Relief administratively and in United States Tax Court.
- Abatement of Accuracy-Related Penalties at the individual level, which originally arose from a TEFRA Partnership Tax Court Decision.
- Concession of return preparer penalties at examination and administrative appeal levels, and avoidance of return preparer injunction referrals.
- Offer-in-Compromise (Doubt as to Liability) concession of approximately $400,000 in tax, interest, and penalties due to acceptance of previously unallowed casualty-theft loss.
- Concession of nearly $7 million in previously disallowed losses before the Franchise Tax Board Protest Section.
- Agreement to no-tax-due and to previously unclaimed losses after the IRS initially asserted over $600,000 of additional income from an erroneous bank deposit analysis.
* The outcome of each case is determined by its unique facts and circumstances. The above highlighted cases are not suggestive of future results. Tax attorney Daniel W. Layton, Esq., makes no promises or representations as to the results of any client’s case.