“Black Letter Law in Innocent Spouse Cases:
a. Res Judicata Did Not Bar Claims for Relief: In Deihl v. Commissioner, 134 T.C. 156 2010), the Court held that the doctrine of res judicata, as set forth in I.R.C. § 6015(g)(2), did not preclude a requesting spouse from raising the issue of relief from joint and several liability for tax understatements, penalties, and interest under I.R.C. § 6015(c) for one of three years that were the subject of prior litigation or under I.R.C. § 6015(b), (c) and (f) for the other two years. In so ruling, the Court held that the exception to the application of res judicata in I.R.C. § 6015(g)(2) applied to the wife’s claims because the wife did not meaningfully participate in the prior litigation and relief from joint and several liability under I.R.C. § 6015(c) was not an issue in the prior proceeding for one year and was not an issue under I.R.C. § 6015(b), (c) and (f) for the other two years.”
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Frank Agostino is the president of Agostino & Associates, P.C., a law firm in Hackensack, New Jersey specializing in civil and white collar criminal litigation, tax controversies and tax planning. Prior to entering private practice, he was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey; he also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases.
Dennis Brager if the founder of the Brager Tax Law Group – a worldwide practice limited to representing clients having criminal and civil disputes with the IRS, the California Franchise Tax Board, the State Board of Equalization and the Employment Development Department. He is a former Senior Trial Attorney for the Internal Revenue Service’s Office of Chief Counsel. Mr. Brager is a California State Bar Certified Tax Specialist.
Agenda
Faculty
Dennis Brager
Brager Tax Law Group
- Founder of the Brager Tax Law Group – a worldwide practice limited to representing clients having criminal and civil disputes with the IRS, the California Franchise Tax Board, the State Board of Equalization and the Employment Development Department
- Former Senior Trial Attorney for the Internal Revenue Service’s Office of Chief Counsel
- California State Bar Certified Tax Specialist
- Frequent lecturer at the UCLA Tax Controversy Institute and University of Southern California
- Appeared on ABC’s Television show Good Morning America, Fox Business News, KFWB Money 101, and KABC’s The Larry Elder Show
- Author of articles that have appeared in California Lawyer, Daily Journal, Taxation for Lawyers, Los Angeles Lawyer, The Consumer Advocate, Family Law News, California Tax Lawyer, Journal of Tax Practice and Procedure, Journal of Tax Investments, and Marijuana Venture
- Quoted as a tax expert by Business Week, The Daily Journal, The Daily Beast, USA Today, Tax Analyst, The Chicago Tribune, CNN Money, Bloomberg BNA, Accounting Today, Tax Notes Today, and The National Law Journal
- Former chair of both the Tax Compliance, Procedure and Litigation Committee of the Los Angeles County Bar Association and the California State Bar, Tax Procedure and Litigation Committee
- Can be contacted at 310-208-6200 or www.bragertaxlaw.com
Frank Agostino
Agostino & Associates
- President of Agostino & Associates, a law firm in Hackensack, New Jersey specializing in civil and white collar criminal litigation, tax controversies and tax planning
- Prior to entering private practice, he was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey; he also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases
- Frequent speaker and author on tax controversy and litigation matters
- Serves on the advisory board of the Journal of Tax Practice and Procedure; actively involved with the American Bar Association and the New York County Lawyers’ Association
- President of the Taxpayers Assistance Corp., which provides tax and legal advice to low income taxpayers in the NY/NJ area
- J.D. degree, New York Law School; B.A. degree, City College of New York; LL.M. degree in taxation, New York University School of Law
- Can be contacted at 201-488-5400 or [email protected]
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