
Dedicated to helping our clients keep what's theirs
- "Yahnian Law Corporation obtained results for us against the IRS that no one else we had been to could" Richard C
- "Other attorneys and CPAs said our case was a certain loser when we went to see them about representation, but Yahnian Law Corporation took over the matter and won it for us." Tom
- "If you're not asking for or getting tax planning advice, you are not saving taxes, and, in fact, may be paying more taxes than you legally owe." Steve Yahnian
- "When dealing with the taxing authorities, attack when appropriate, retreat when strategically necessary, and stand your ground when neither of the first two options are available or necessary. The secret is knowing when you are in one or the other of the circumstances that evokes which position to take." Steve Yahnian
- "Ever wonder why the IRS calls it Form 1040? Because for every $50 that you earn, you get 10 and they get 40." Anonymous
- "It ain't over till it's over." Yogi Berra
We have achieved many successes, oftentimes far better than expected, for those who have been audited by or owed taxes to the taxing agencies, IRS and California. We have handled a large number of such cases and have many years of in depth experience. Following is a small sample of the many matters we have successfully and victoriously handled.
- A CPA had represented a client on a U.S. Tax Court matter against the IRS. Just prior to the time of trial, the CPA and client hired Yahnian Law Corporation to take over the matter scheduled for trial in less than a week. Tax liability reduced by 50%.
- The Client's CPA prepared a tax return indicating a large tax liability due to debt forgiveness. Client could not pay the tax. IRS and FTB began to seize the client's tax refunds. The Client came to us. Through investigation, we discovered that the debt had been forgiven through bankruptcy, making the cancellation of debt not taxable to the client. Amended tax returns were prepared and filed for Client. Client not only had the tax debt go away, they received a refund, with interest, from both the IRS and FTB.
- The Client had been assessed $350,000 in payroll taxes and an SBA loan default. Through Offers in Compromise with each governmental agency prepared and submitted by Yahnian Law Corporation, the amount that was settled for and paid totaled $36,000. The matter closed. Client got his life back.
- On a large tax matter, we obtained results for the client that no other Attorney or CPA had been able to obtain. The client had been to two other law firms and a CPA firm before he came to Yahnian Law Corporation.
- Saved client's retirement plan from levy by the IRS.
- Client failed to pay IRS payroll taxes on employee salaries amounting to $1,300,000 with interest and penalties, due to failing business. IRS began collection. Client attempted several offers in compromise with IRS on their own, failing each time. With the prospect of losing their assets and having their wages garnished, clients hired Yahnian Law Corporation to represent them. Yahnian Law Corporation worked out a settlement of the tax debt for a payment of $72,000. IRS released their liens and client got their life back and a fresh start.
- Formulated and implemented a business and tax plan saving client substantial taxes
- Yahnian Law Corporation battled the IRS in U.S. Tax Court on a 4 million dollar assessment that appeared hopeless to the client, other attorneys, and its CPA. The matter was settled for 50 cents on the dollar.
- In a case of gaining victory in what looked like certain defeat to the client, the client, facing a daunting $150,000 EDD assessment as a 'responsible person' of the corporate employer (that did not pay over payroll taxes), was found not liable by the administrative judge, after the administrative hearing.
- A client and his spouse came into the office with a $2,000,000 plus federal income tax bill. Based on the facts they told me, some tax liability was owed, but not to that extent. They had ignored a notice from the IRS that would have allowed them to challenge the assessment in Tax Court and without first paying the tax liability. As a result, their choices were severely limited by the time they saw me. However, I immediately took the only steps that were possible to challenge this assessment without paying any taxes. At that point the only courts with jurisdiction would have been the U.S. Federal District Court or U.S. Claims Court in Washington, D.C. But, those courts can only hear cases where the Taxpayer pays the taxes first. Of course, this was not feasible. I took a different approach and was able to get IRS to reduce the assessment from $2,000,000 to approximately $300,000 without having to go to court.
- The Client had been audited by IRS. IRS assessed the Client nearly $40,000 in taxes, interest and penalties. At that point, the Client contacted and hired Yahnian Law Corporation to fight the IRS and their assessment. Yahnian Law Corporation took immediate steps to prove that the IRS assessment was in error. This involved a thorough review and analysis of Client's books and records as well as advocacy to the IRS auditor. Verdict: IRS agreed to reduce the assessment to under $200. Yahnian Law Corporation achieved a surprising and complete turn-around victory for the Client.
- California State Board of Equalization assessed purchaser of motor home use taxes from purchase of RV that was to be used out of state. We obtained complete exoneration of tax assessment. Client owed nothing.
- IRS disallowed over $1,500,000 in deductions on a farmer's tax returns. Farmer's CPA referred the farmer to this office. Pursuant to the filing of a US Tax Court petition and advocacy by this office on behalf of farmer, IRS reduced the assessment to under $100,000.
- Taxpayer was assessed substantial penalty for alleged failure to file magnetic version of w-2s with Social Security Administration. IRS asserted failure to file penalties as a result. Yahnian Law Corporation advocacy based upon SSA computer failure to read client disk, not client, was the cause. IRS abated the penalty in full.
- CPA referred client under IRS audit. IRS attempted to disallow several million dollars in losses that taxpayer client had taken on the basis of lack of ‘material participation ‘in several small businesses and payment to himself of excess compensation by his corporation. We determined that little used section of the Internal Revenue Code allowed grouping of different taxpayer businesses in order to meet ‘material participation’ test so that ALL of those businesses when combined met the test. Also, convinced IRS that the compensation was reasonable, after all based on the law and the applicable facts and circumstances. Result: all tax losses allowed and tax savings of over one million dollars to client.
- Client came to us after the IRS has assessed the trust fund penalty against him from a corporate business of which he was part owner and President. The IRS found that he had the authority to sign checks, get loans and bind the corporation contractually with third parties, all badges the IRS is looking for to impose personal liability for unpaid Corporate payroll taxes. However, he had not been involved in the corporation's day to day administrative operations, but was in the field each day actually conducting construction activities. We were able to obtain a very favorable offer in compromise for the client where he settled the over one million dollar assessment for less than $10,000.
- Client came to us after IRS had threatened to assess the trust fund penalty against her. She was the Corporation's bookkeeper and was coerced by the Corporation's President to forego paying payroll taxes but instead to pay other creditors. IRS audited and determined that they were going to assess the penalty against her. At that point, Client came to us. She then hired us to defend her against the IRS. We did substantial research of the facts and applicable case law in her favor, preparing a tax brief establishing the arguments totally exonerating her. On appeal, we convinced IRS she was not a 'responsible person'. Thus, no assessment was made against her.
- Client prepared their own tax return and subsequently were audited by the IRS. We took over the audit, found a large tax deduction that the client had overlooked, and successfully and substantially reduced the proposed IRS assessment.
- Client transferred real property to a new LLC they had created for estate planning purposes. County assessor assessed increase in property taxes alleging 'change in ownership' of the real property, which gives legal basis for reassessment of property for property tax purposes, resulting in tax increases. Annual property taxes were substantially increased by the Assessor. Client retained us to challenge the increase. We discovered that the transfer qualified for an exception to the 'change in ownership' rules. We prepared a written analysis with supporting evidence to refute the increase and submitted it to the Assessor. Assessor agreed with our arguments and completely rescinded the increase in property taxes. We achieved complete victory for the client.