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David Dickieson’s representation of a tax return preparation business owner resulted in a substantial reduction of IRS penalties that had been assessed against the owner for the allegedly negligent preparation of almost 500 tax returns. The penalty reduction — from $249,000 to only $81,500 — makes the business owner eligible for an award of attorney’s fees as the “prevailing party” against the IRS. Mr. Dickieson will seek further reduction and/or elimination of the remaining penalty in a case to be filed in the United States Court of Federal Claims.
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