Tax Law

Your tax matters can be handled in a sophisticated and cost-effective manner by Susan Berson. A former Senior Trial Attorney with the Tax Division of the U.S. Department of Justice, Susan has two decades of experience in all phases of administrative, audit, enforcement, collection, appeals and regulatory action. She is also the author of the treatise, Federal Tax Litigation (Law Journal Press), which she is responsible for updating twice a year.

Susan draws on her experience representing the IRS early in her career to help clients understand the IRS playbook.
Susan advises clients in a variety of industries, markets and professions about tax audits, tax compliance and reporting obligations, entity selection and developing best tax practices, and recent legislative changes which impact their industry-specific practices, professions and wealth preservation opportunities. When litigation is on the horizon, Susan is also admitted in state and federal district, bankruptcy, and tax courts to handle such matters. Accounting, financial and legal professionals also retain Susan for consultations about audit strategy, responding to IRS information and document requests, appealing agency determinations, pursuing administrative relief, litigating issues in court, analyzing the tax consequences of entity selections, mergers/sales, loan transactions, severance, settlements, judgments, dischargeable tax debt in bankruptcy, tax-related investments, wealth management and preservation strategies/proactive retirement planning measures.

Audits. Many taxpayers mistakenly plunge into an audit flying solo, without the aid of an attorney or other professional. However, negotiating and responding to IRS information/ document requests is an important part of an audit process. It is imperative that a balance be attained between providing the information that the IRS may legitimately need, while protecting taxpayer privileges and limiting information requests to a rule of reason. The IRS has increasingly been involving its attorneys early on in the audit examination process. Because of this, our experience has been that it can be crucial to a taxpayer’s success to have legal counsel before revealing information to the government. In that regard, we have experience planning for, and managing audits, as well as various audit issues such as responding to information document requests, complying with formal document requests, quashing summonses, controlling statutes of limitation, establishing document retention procedures, and identifying and protecting privileged documents. This practice area includes experience with various special IRS programs such as the Coordinated Examination Program, the Large Case Program, the Industry Specialization Program, the Market Segment Specialization Program, the Early Referral Program, the Appeals Coordinated Issues Program, the Advance Pricing Agreement Program, and the Tax Preparer and Tax Promoter Programs.

Withholding Taxes, Sales Taxes, Use Taxes.
The IRS and state departments of revenue routinely focus on withholding requirements for businesses and employers. This is especially pertinent to service industry professionals --from attorneys, doctors, dentists, to cash-based businesses, such as restaurants, spas and salons to technology and “IT” contractors—where an IRS revenue agent or state tax auditor is statutorily charged with the responsibility of carefully scrutinizing the withholding and proper payment of taxes practices employers may implement when hiring independent contractors and employees. Susan Berson has significant experience handling IRS audits and state sales and use tax audits, appeals and controversies. From pre-planning review to implementation of proper record keeping practices to handling actual audits, appeals, and defending officers who may be surprised to find that the government is assessing them for the unpaid tax liabilities of their businesses. If you are the owner, officer or director of a business facing audit scrutiny from the IRS, or states of Missouri and Kansas, Susan can help you evaluate your circumstances, including an honest analysis of the most cost-effective options to move forward and continue with your operations’ goals.

Troubleshooting Tax Planning, Trusts and Wealth Preservation Matters. Tax issues can arise from business transactions, investments, trusts, and even certain accounting practices. We consult with financial professionals such as accountants, C.P.A.‘s, certified financial advisors, investment and wealth managers, as well as their beneficiaries and customers, respectively, concerning the potential consequences of bequests, entity selections, mergers/ sales transactions, severances, settlements, tax-related investments, and proactive planning measures. Evaluating potential adverse tax consequences that can harm the tax, financial management and wealth preservation goals of a financial professional’s customers, including trust beneficiaries, respectively, are matters in which Susan can help.

Analysis of Pre-Bankruptcy and Post-Bankruptcy Options. We provide advice concerning the dischargeability of IRS and state tax debts to bankruptcy lawyers who represent business debtors, lenders and/or institutional creditors.


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Susan Berson
(913) 397-2702 (Tel)
(816) 510-0179 (Mobile)
(913) 273-0747 (Fax)
sberson@banktaxlaw.com

This website provides general information about legal issues and developments in the law. Such materials are for informational purposes only and may not reflect the most current legal developments. These informational materials are not intended, and must not be taken, as legal advice on any particular set of facts or circumstances. You need to retain an attorney for advice on specific legal issues.

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