Barbara T. Kaplan

Experience: Civil Tax and ERISA Litigation:; Represented foreign corporations in litigation involving transfer pricing and other valuation issues; represented welfare benefit plan in ERISA litigation involving claim for benefits, tax consequences of participation in plan and related actions; represented estate of decedent in U.S. Tax Court in challenge of family limited partnership; represented limited partnerships with investments in motion pictures, commodity straddles, equipment leasing, oil and gas, real estate, nurseries, cattle raising and horse breeding in U.S. Tax Court; litigated and appealed a leveraged buy-out of a U.S. corporation with an international seminars business; litigated bad debts and other business expenses of a U.S. manufacturing business; settled Tax Court proceeding for construction company and its shareholder charged with tax fraud; refund litigation in Court of Federal Claims; interpleader action in Federal District Court to recover funds claimed by both IRS and the State.; Administrative Tax Proceedings:; Handled sensitive audits, offshore account reporting and audits, penalty waiver and abatement claims, unified partnership (TEFRA) proceedings, refund claims, facade easements, charitable contributions, transfer tax, tax shelters, REIT compliance, federal and state non-resident issues, unincorporated business tax, independent contractor/employee issues, transfer pricing, unreasonable compensation cases, penalty abatement, interest abatement, back-up withholding, accumulated earnings tax and sales and use tax cases.; Tax Collection Problems:; Negotiated installment payment agreements, offers in compromise, collection freezes, interest and penalty abatements and cancellation of jeopardy assessments; removed tax liens and advised on transferee liability issues.; Tax Fraud:; Completed voluntary disclosures involving undisclosed offshore accounts, non-filers and tax fraud; represented corporations and individuals in federal and state administrative and grand jury criminal tax and related investigations; negotiated plea agreements; defended taxpayers in summons enforcement proceedings; represented and counseled taxpayers in cash reporting compliance checks, audits and government stings in the automotive, boating and motorcycle industries, among others; quashed subpoenas and IRS summonses.; Tax Professionals:; Represented tax professionals before the IRS Office of Professional Responsibility in suspension and disqualification proceedings; advised tax professionals in connection with their duties as preparers and under the Internal Revenue Code and in advising their clients; counseled on compliance with Circular 230.; Government Experience: Trial Attorney, Regional Counsel, Internal Revenue Service; Senior Trial Attorney, District Counsel, Internal Revenue Service; Instructor, Criminal Tax Attorneys Training Program, Internal Revenue Service