Situation
A leading public accounting firm faced $780,000 in late filing penalties and interest over a final tax return it filed for a holding company that had dissolved an entity months earlier as part of a restructuring. The Internal Revenue Service determined the tax return had been filed too late.
Result
Husch Blackwell successfully argued that when the final return was filed, the entity still existed for tax purposes, even though it did not exist for state law purposes. All fees and penalties were eliminated, saving our client $780,000.
Husch Blackwell Team: Robert M. Romashko