Tel: (804) 915-7030
Fax: (804) 915-7037

 

Dick Davis has been named among Virginia's
Legal Elite
by Virginia Business

Serving Virginians for a Quarter Century

 

 

Tax & ERISA Controversy Practice

       
 

Tax Controversy

  • U.S. Tax Court
  • IRS Appeals
  • IRS Audits
  • Tax Fraud Defense
  • Offers in Compromise
  • Responsible Person Defense
  • Virginia Income/Sales Tax Disputes

ERISA/Qualified Plans

  • IRS Voluntary Compliance (EPCRS)
  • DOL Fiduciary Compliance Filings
  • DOL Investigations
 
       
 

Representative Tax & ERISA Controversy Experience:

  • 82 percent concession by government on appeal of disallowance of $50 million in deductions claimed by publicly traded company.
  • 65 percent concession by government on fraud penalty asserted against taxpayer even though taxpayer had been criminally convicted on indictment for filing false return for the taxable year in question.
  • Successfully defended business owner in tax evasion case where the IRS Criminal Investigation Division accused taxpayer of not reporting one half million dollars in cash receipts.
  • Successful defense of executor charged by IRS with liability for estate's unpaid taxes.
  • Achieved reversal of $2 million pension plan funding deficiency assessed against sponsor of tax qualified plan by Department of Labor.
  • Exoneration of executive assessed one half million dollars in responsible person penalties.
  • $50,000 settlement of estimated one half million responsible person penalty assessed against CFO.
  • Two thirds concession by government relating to $600,000 responsible person assessment made against CEO.
  • Several very favorable voluntary compliance and closing agreement program (“CAP”) settlements for qualified retirement plans with disqualifying features.
  • Favorable settlement of reasonable compensation case.
  • Several successful reasonable cause applications made for waivers of very substantial failure to deposit, non-filing, and/or late filing penalties.
  • Successfully applied for 501(c)(3) tax exempt status of trust (retroactive 20 years) on behalf of a major financial institution serving as trustee.