Freeman Freeman & Smiley’s Joseph Mudd Secures Favorable Rulings From Federal and State Tax Authorities

Joseph E. Mudd recently received full concession from the IRS Area Counsel and Stipulation for No Change Tax Court Settlement on behalf of a corporate business client.  who was in receipt of a notice of assessment after audit, proposing an income adjustment of more than $800,000.00 resulting in tax, penalty and interest of more than $300,000.00.  When IRS Appeals refused to settle the case, a petition was filed against the Commissioner of the Internal Revenue Service in US Tax Court.  IRS Area Counsel in Los Angeles fully conceded the case.

In a related matter, Mr. Mudd recently obtained judgment in LA Superior Court for full refund of payment made to the Franchise Tax Board by our client, in an amount in excess of $116,000.00.  The Franchise Tax Board had consistently refused to abate the tax liability that Mr. Mudd  asserted was improperly assessed by the State.  A suit against the State of California for refund was filed, and.  after rejecting an offer for a partial refund, the California AG’s office agreed to a full refund before trial.