We were engaged by counsel for the Petitioners in a civil IRS matter to provide an analysis that would explain numerous transactions between the Petitioners and various non-profit entities totaling over $20 million that the IRS alleged to be an unreported income. Our work consisted of reviewing the IRS’s Notice of Deficiency, bank account information related to the Petitioners and the non-profit organizations, and other supporting information. We analyzed the transfers between the Petitioners’ bank accounts and not-for-profit organizations’ bank accounts to determine the amount of cash receipts in the Petitioners bank accounts that should have been classified as loan repayments, thereby, reducing the amount of unexplained deposits included on the IRS’s Notice of Deficiency. We determined the amount of unexplained income on the IRS’s Notice of Deficiency was overstated and, therefore, the underpayment of income tax should have been reduced. Our work was used by counsel to negotiate a favorable settlement on behalf of the Petitioners.

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