- In U.S. Tax Court litigation, represented an Atlanta-based corporation facing $30 million in additional taxes, penalties and interest. Prior to trial, obtained a 100 percent concession from the IRS. First Multiple Listing Service, Inc., v. Commissioner, U.S. Tax Court No. 25141-14.
- In U.S. Tax Court litigation, represented a Puerto Rico-based corporation facing substantial additional tax liabilities based on the IRS’s assertion that it failed to report U.S.-sourced income effectively connected with a U.S. trade or business. Obtained a settlement prior to trial reducing the proposed additional liabilities by more than 90 percent. Kiyavi Corp., v. Commissioner, U.S. Tax Court No. 008021-14.
- Represents multiple clients with the disclosure of foreign bank accounts through the IRS’s Offshore Voluntary Disclosure Program (OVDP).
- Represented an executive of a multinational corporation during an IRS criminal investigation involving failure to disclose Swiss bank accounts. Convinced the IRS to drop the investigation.
- Represented the owner of a manufacturing business during a U.S. Department of Justice criminal investigation involving failure to disclose foreign bank accounts. Convinced the Justice Department to drop the investigation.
- Represented a business owner during a three-year grand jury investigation involving allegations of failure to pay more than $20 million in payroll tax obligations. Convinced the Tax Division of the U.S. Department of Justice to decline prosecution.
- Represented a business owner in U.S. Tax Court litigation where the IRS relied on the “net worth” method to prove income. After demonstrating that the IRS’s net-worth calculations contained numerous errors, obtained a settlement reducing the IRS’s proposed tax liability by 95 percent. Patel v. Commissioner, U.S. Tax Court No. 016960-06.
- In U.S. Tax Court litigation, represented the owner of a trucking company accused of embezzling funds for personal use. Following trial, the court reduced the tax, penalties and interest asserted by the IRS by 90 percent. Prater v. Commissioner, T.C. Memo. 2011-68.
- Represented an investment advisor during an IRS criminal investigation of an alleged Ponzi scheme. Convinced the IRS to drop the investigation.
- Represented an investment advisor during the course of a federal grand jury investigation involving allegations of mail fraud, wire fraud and securities fraud. The investigation was concluded with no charges brought against the client.
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George offers his clients confident guidance through civil and criminal tax controversy matters. He honed his skills as a federal prosecutor for the Department of Justice, where he was recognized by former Attorney General John Ashcroft as a Tax Division Outstanding Attorney.