Representative Work

Representative Work: Constructive Dividend

A client ran a construction business as a C-corporation. The IRS audited and asserted that the client's compensation was unreasonably high and recharacterized a significant portion of the compensation, as well as a well documented loan to a shareholder, as a constructive dividend. This resulted in the assertion of a double tax by the IRS.  In taking the matter to appeal, we succeeded in substantially supporting the taxpayer's position.

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