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Joseph E. Mudd Receives More Than $150 Million Concession for Clients From Franchise Tax Board

August 3, 2016

Of Counsel, Joseph E. Mudd, received a total concession on behalf of his clients of more than $150 million from the Franchise Tax Board (FTB) for taxes which FTB proposed to assess against four related individuals and four irrevocable trusts for the tax years of 2006-2008, and two additional unrelated individual minority owners of a flow-through entity, which the FTB identified as a tax shelter under California law.  The combined proposed assessments included tax, penalties, and interest.  

The audit began in early 2011 with the first protests filed in December 2011 for years 2006 and 2007, and protests for 2008 filed in December 2013. The FTB allowed the statute of limitations to expire on 2009 and 2010, and dropped its audit of 2011.

Mr. Mudd specializes in the area of tax controversy with extensive experience in tax audits, appeals, tax litigation, refund litigation and tax planning. As a former Senior IRS counsel, having worked for IRS District Counsel from 1987 – 1990, Mr. Mudd applies that experience with his specialized taxation law education from NYU in helping hundreds of clients, both individuals and businesses, navigate their controversies through successful resolution with the IRS, California State Board of Equalization (SBE), EDD, and Franchise Tax Board (FTB). He has successfully represented clients with asserted tax liability from as little as $50,000 to more than $150 million involving numerous factual and legal issues.