Tax Accounting Group

Resources and Versatility

When you engage TAG, we deploy our entire team and network of resources. By drawing upon the experience and versatility of our professionals, our integrated multidisciplinary approach and the efficient interaction between our lawyers, certified public accountants, certified fraud examiners, financial consultants and analysts, we believe that we are uniquely qualified to provide analysis and services of the highest quality.

Our Team

What allows TAG to fulfill our mission and maintain long-term relationships with our clients is the passion, objectivity and deep experience of our professionals. Our senior staff has an average of about 25 years working together as a team, with some having more than 35 years on our platform. These professionals are intimately familiar with and take a personal interest in client needs and work hard to justify the trust placed in TAG.

As the entrusted advisor to clients in every U.S. state and 25 foreign countries, TAG continues to enjoy impressive growth, in large part because of our clients' continued expression of confidence and referrals.

Range of Services

We offer an array of services, including tax compliance and planning, accounting, management advisory services, analyses of all kinds, best-worst case studies and litigation consulting services in a variety of industries and fields on one platform.

Personalized Attention

We believe that personalized service and attention maximizes the opportunity to meet the needs of our clients. TAG managers and other professionals are available to discuss any questions or issues that may arise. Our policy is to accept all telephone calls immediately and, if that is not possible, to return calls within 24 hours. While others claim to provide exceptional services and personal attention, TAG delivers it.

Regular Communication

We emphasize strong communication with our clients. In addition to personal and regular contact, we provide to our clients on a complimentary basis Client Alerts highlighting recent developments in the fields of taxation, litigation consulting and accounting, as well as other periodic tax and financial publications designed to be used as reference guides throughout the year.

Technical Proficiency and Quality Control

We believe in providing our clients with efficient and cost-effective technical proficiency. When you engage us, you have access to our entire team and all of our combined resources. We have established rigorous internal quality control systems, and our review procedures are consistent with the guidelines established by the American Institute of Certified Public Accountants (AICPA) and best practices.

Innovative Ideas

With a great sense of urgency, we strive to offer innovative ideas and problem-solving ability in tax, accounting, financial, operational, managerial and litigation matters to enhance client success.

Experience in Various Industries

We have experience in a wide range of markets, including more than 60 service lines in more than 45 industries. This experience broadens our capabilities and enhances our ability to identify, confront and resolve a variety of issues and concerns.

Competitive Fees

Our rates are typically 30% less than the largest CPA firms and compare favorably to mid-sized firms.

Convenient Locations

With offices in major markets, we serve clients throughout the country and internationally.

Confidentiality

Privacy is as important to us as it is to our clients, and maintaining trust and confidence is one of our highest priorities. Client records are confidential and carefully secured in TAG's offices.

Selecting an adviser, whether an expert or consultant, is one of the most important decisions you will make. With TAG, you get the best of both worlds. You benefit from TAG's quality and highly personalized professional services backed by the solid reputation of Duane Morris. This one-of-a-kind platform allows us to deliver flexible, customized and specialized services desired by our clients while providing uncommon and convenient access to other valuable resources and services in the legal and non-legal fields.

TAG believes that it is through our personal relationship with you that we can most efficiently address your total tax, financial, accounting and, if necessary, litigation needs. We often hear from our clients that while our firm is large enough to serve their various needs, we also take a remarkable personal interest in them and are intimately familiar with their needs. When it comes to serving our clients, we combine the advantages of a regional CPA practice with the convenience and efficiency of accessing the resources of an international law firm of more than 900 lawyers, drawing on the legal, administrative and technological services of the firm's international network of offices. A small sampling of advantages of engaging TAG as your tax service provider, expert or consultant include:

• Highly personalized service and attention
• Unique multi-disciplinary team and network of resources
• Efficient and cost effective services
• Convenient locations to serve clients throughout the country and internationally
• Proactive communication, newsletters and client alerts on relevant and timely topics
• Confidentiality
• Competitive fees
• Innovative ideas and problem-solving
• Convenient, quick and uncommon "one stop" access to other valuable services in the tax, accounting, financial and legal fields
• Experience in over 60 service lines in more than 45 industries
• Unparalleled sense of urgency

Tax Compliance, Planning and Consulting

Traditional Services Provided in an Innovative Manner

TAG provides a wide range of federal, state and local tax compliance, planning and consulting services to individuals, businesses, tax-exempt entities, and estates and trusts. We provide services to clients in every U.S. state and 25 foreign countries. Our taxation services include:

• Tax Compliance
• Tax Equalization Calculations
• Tax Negotiation
• Tax Planning
• Tax Provision and Accruals
• Tax Representation
• Tax Research
• Tax Strategy Development

Range of Services

For Lawyers, Law Firms and Corporate Law Departments

TAG offers a variety of consulting services to lawyers and law firms representing clients in regulatory and transactional matters and throughout various stages of litigation. Our practitioners assist in the pre-trial and discovery phases and at trial, including:

• Alter Ego Analysis
• Analysis and Rebuttal of Opposing Expert Reports
• Antitrust/Business Combinations
• Asset Recovery Investigations/Locator Services
• Assist in Demonstrative Preparation Including Developing and Preparing Exhibits For Trial
• Assess Compliance with Generally Accepted Accounting Principles and Auditing Standards
• Assist in Pre-Trial Settlement and Other Conferences and Negotiations
• Bankruptcy
• Breach of Contract
• Business Intelligence/Reporting
• Business Valuation
• Case Assessment, Strategy Development and Exposure Analysis
• Commercial and Contractual Disputes
• Comprehensive Analysis of Complex Financial Data
• Cross-Examination Strategy Development
• Damage Assessment and Measurement
• Database Management, including Database Design and Development
• Draft Interrogatory and Deposition Questions, Subpoenas, Stipulations, Document Requests, Petitions and Motions
• Employment Discrimination
• Expert Witness Testimony
• Forensic and Investigative Accounting
• Fraud and Embezzlement Detection and Assessment
• Fraudulent Conveyance Reviews
• Identify, Locate and Interview Witnesses
• Internal Corporate Investigations
• Marital Disputes
• Piercing Corporate Veil
• Professional Malpractice
• Regulatory Investigations
• Securities Fraud Damage Modeling
• Shareholder Disputes
• Structuring Settlements
• Successor Liability Analysis
• Taxation

For Individuals and Businesses

TAG offers an array of advisory services to assist individuals and businesses in reaching their goals. Our practitioners assist with:

• Accounting
• Analyzing Debtor Viability
• Bankruptcy Trustee Support
• Budgeting and Forecasting
• Business Due Diligence Investigations
• Business Performance Analysis
• Compliance Reviews including GAAP, Regulatory and Contractual
• Debt Restructuring
• Developing Key Performance Indicators
• Earnings and Profits Analysis
• Entity Selection and Restructuring
• Escrow Agent Services
• Evaluation of Complex Transactions
• Financial Modeling and Analysis
• Financial Statements
• Improvement Studies
• Mergers and Acquisitions
• Operational Studies
• Organizational Development
• Preference Analysis
• Quality of Earnings
• Risk Management Analysis
• SEC Mock Audits
• Strategic Business Planning
• Succession Planning
• Transaction Structuring and Negotiations

As part of our litigation consulting services, TAG performs various in-depth investigation services to assist litigation attorneys in the following areas:

• Location searches (skip tracing)
• Background information identification
• Business and individual credit reporting
• Criminal record searches
• Public record searches, including bankruptcies, claims, judgments, lawsuits, liens and UCC filings
• Recorded asset identification, including real property, vehicles (where permitted by state law), aircraft, watercraft and safe deposit boxes
• Asset valuation, including encumbrance identification and equity valuation
• Liquid asset identification, including bank accounts, investment accounts, patents and trademarks
• Account monitoring
• Service of process
• Private investigation services (via strategic alliances)
• Likelihood of recovery assessment

Our practitioners utilize a broad source of tools and resources to collect, organize and analyze data in order to locate subjects, assess recoverability and recommend recovery actions. All investigations are performed in compliance with the Gramm-Leach-Bliley Act and Fair Credit Reporting Act.

• Represented a retired investment advisor before the New York State Department of Taxation and Finance Audit Division and successfully arranged for the elimination, in full, of nearly $500,000 in assessed liability (including tax, interest and penalty) by identifying errors in the application of New York State tax law. Additionally, while the protest/appeal statute of limitations was closed, which barred the legal right to dispute the assessment, we identified a strategic alternative to re-open the matter to dispute and cancel the assessment.
• Represented one of the largest state-sponsored public pension funds in the nation before the Collection Division of the Internal Revenue Service and settled the dispute along with the complete elimination of $30 million in civil penalty assessments related to the alleged failure to make proper and timely federal tax deposits.
• Represented a large Philadelphia based, multi-service non-profit before the Appeals Division of the IRS in a multi-year audit which successfully resolved a Third Party Payer Arrangement and the related employer’s Federal employment tax withholding, reporting, and tax payment responsibilities, including more than $100,000 in relief from federal payroll tax liabilities, interest and penalties.
• Represented a high net worth individual, internationally recognized in the scientific research and development community, before the Internal Revenue Service’s Examination Division in a comprehensive hobby and business loss audit. The examination resulted in a "no change" income tax report and full allowance of claimed losses.
• Represented a national investment management company in a multi-year, multi-jurisdictional investment and business tax dispute resulting in elimination of 100 percent of assessed penalties and overall tax, interest and penalty savings of $130,000.
• Represented a Big Law Partner before the New Jersey Income Tax Audit Branch in a multi-year state tax credit audit successfully arguing the allowance of nearly $50,000 of non-resident state tax credits.
• Represented a high net worth couple, one of whom was an internationally recognized business consultant, before the Internal Revenue Service’s Examination Division then Appeals Division in a three year Hobby and Business Loss audit, including home office examination, resulting in a total IRS concession of 80% of the tax and penalties.
• Represented a high net worth individual before the Internal Revenue Service and arranged the elimination, in full, of more than $110,000 in civil penalty assessments related to erroneous processing by IRS of annual reporting of transactions related to certain foreign gifts, along with the reversal of all statutory interest.
• Represented multiple, unrelated class of lawyers before the Maryland Department of Revenue in the identification and pursuit of state tax refunds based on a new and little known Maryland Controller Administrative Release permitting a tax credit against Maryland taxes for taxes paid to new and expanded local tax jurisdictions resulting in six figure refunds plus interest.
• Represented a patriarch of a family office before the New York State Department of Taxation and Finance in a five-year Tax Residency audit resulting in a Pennsylvania residency determination, a New York "non-resident" tax status and six-figure state tax savings. Over the past several years, New York has conducted Tax Residency and Domicile audits targeting those who work in New York, maintain a residence in New York or have relocated out of New York to other lower tax states.
• Represented a Political Action Committee (PAC) in a multi-tax and multi-jurisdictional tax examination and voluntary disclosure application before the Pennsylvania Department of Revenue, Pennsylvania Department of Labor and City of Philadelphia resulting in the elimination of penalties, successful completion of the examination, full compliance, and a fresh start.
• Represented a national provider of personal care and skilled health services before the Examinations and Collections Divisions of the Internal Revenue Service in a multi-year employment tax audit resulting in the elimination and reversal of a six figure tax assessment and a recovery of more than a five figure refund of overpaid employment taxes, as well as removal of filed tax liens.
• Represented a high net worth couple before the Wisconsin Tax Appeals Commission in a state tax credit dispute relying on the landmark U.S. Supreme Court case, Comptroller of the Treasury of Maryland v. Wynne, resulting in a 100% concession by Wisconsin.
• Represented an Officer and a leading independent investment advisory firm before the Collection Division of the Internal Revenue Service and the National Taxpayer Advocate Office and arranged the elimination of more than of $600,000 in jointly assessed penalties resulting from an erroneous assessment made by the IRS.
• Represented a boutique jewelry and luxury goods business before the Pennsylvania Board of Appeals related to a sales tax audit and assessment for multi-year reporting periods resulting in a Board Decision and Order reducing the proposed deficiencies by 96%.

• Represented one of the top 100 universities worldwide before the City of Philadelphia Department of Revenue related to delinquent wage tax liabilities resulting in the elimination of more than $500,000 of tax, interest and penalty, ending a long standing dispute with the City.

• Represented a senior executive of an international brand management company before the New York State Department of Taxation and Finance in a three year Tax Residency audit resulting in a Pennsylvania residency determination, a New York "non-resident" tax status and state tax savings in excess of $50,000. Over the past several years, New York  has conducted Tax Residency and Domicile audits targeting those who work in New York, maintain a residence in New York or have relocated out of New York to other lower tax states.
• Represented a construction business before the Pennsylvania Board of Appeals related to a sales tax issue resulting in a reversal of the auditor’s findings and tax savings of approximately $25,000.
• Represented an individual beneficiary of three substantial trusts before the Collection Division of the IRS and secured the release of levies on trust assets along with resumption of trust distributions, as well as the elimination of the taxpayer’s $300,000 individual income tax liability by capitalizing on IRS procedural deficiencies.
• Represented a high net worth individual along with multiple controlled businesses before the Appeals Division of the IRS in a multi-day Rapid Appeals Process (RAP) in connection with the Service’s adjustments in  excess of $110 million resulting in an extraordinary settlement and a tax savings of more than $25 million.  RAP is a new, elective alternative dispute resolution method available to certain taxpayers who appealed certain Large Business and International Division (LB&I) sourced cases assigned to the Appeals Division. The LB&I Division typically deals with complicated issues involving tax law and accounting principles.
• Represented multiple physicians before the Large Business and International Division of the IRS, which is responsible for the examinations of businesses and individuals with assets greater than $10 million, in connection with the examination of claimed foreign earned income exclusions, foreign housing exclusions and foreign tax credits. The examination resulted in a “no change” income tax report resulting in a tax savings of approximately $150,000.
• Represented a retired widow before the Collection Division of the Internal Revenue Service and successfully negotiated an installment payment arrangement and the release of levies to facilitate a sale of real estate, the release of a Social Security garnishment, and the waiver of penalties of more than $150,000 while preserving the taxpayer’s retirement assets and valuable intangible property rights.
• Represented a high net worth individual before the Collection Division of the Internal Revenue Service and successfully negotiated a discharge of property from a six-figure federal tax lien within 14 days of application. Typically, the process takes 30-45 days, or longer.
• Represented a lawyer before the New Jersey Income Tax Audit Branch in a multi-year audit, successfully arguing the appropriateness of non-resident state tax credits, thereby eliminating nearly $20,000 in assessed tax, interest and penalty.
• Represented a non-profit community development corporation with more than $4.6 million in assets before the Tax Exempt and Government Entities Division of the IRS to obtain a retroactive reinstatement of tax exempt status. The organization's tax exempt status was revoked for failure to file required annual tax returns for three consecutive years, subjecting more than $3.9 million of gross receipts earmarked for community development to federal and state taxes. The organization saved in excess of $1.3 million in taxes as a result of the successful reinstatement.
• Represented an international architectural, engineering and design company before the Examination Division of the IRS in connection with the Service's examination of a $2.9 million deduction related to the new Energy Efficient Commercial Buildings Deduction under Internal Revenue Code Section 179D as well as other deductions in excess of $60 million resulting in a "no change" income tax report.
• Represented a national real estate investor and consultant before the Examination Division of the IRS in connection with the disallowance of a $3 million deduction of a settlement payment made in lieu of litigation resulting in a "no change" income tax report and a tax savings of approximately $750,000.
• Represented a retired high net worth individual before the Pennsylvania Department of Revenue in a Tax Residency and Domicile audit resulting in a Florida domicile determination, a Pennsylvania "non-resident" tax status and state tax savings in excess of $350,000. Over the past several years, Pennsylvania has conducted Tax Residency and Domicile audits targeting those who have relocated to Florida or other lower tax states.
• Represented a boutique law firm before the IRS Appeals Division and subsequently before the IRS Office of Chief Counsel in connection with the examination of five years of corporate income tax filings prepared by a regional CPA firm resulting in the reduction of tax, interest and penalty of more than $1.2 million.
• Represented a global law firm with more than 500 attorneys in offices across the United States and around the world before the State of Washington, Department of Revenue in connection with the examination of business, occupancy and personal property tax filings resulting in the avoidance of significant penalties.
• Represented an international law firm with offices throughout the United States and abroad before the Audit Bureau of the Illinois Department of Revenue and secured a "no change" income tax report.
• Represented a large Philadelphia based, multi-state, internationally recognized design firm providing professional services in the disciplines of architecture, engineering, interior design, planning and landscape architecture before the Utah State Tax Commission and negotiated the abatement of more than $20,000 in penalties resulting from late payment of non-resident trust fund taxes.
• Represented a large Philadelphia-based architectural firm before the Government Entities Compliance Unit of the IRS in a new Voluntary Classification Settlement Program, which resolved classification of workers for employment tax purposes and obtained substantial relief from federal payroll tax liabilities, including waiver of interest and penalties.
• Represented a national chain of clothing stores before the City of Philadelphia Law Department, arranged filing of five years of unfiled tax returns and successfully negotiated a 30 percent reduction in tax, interest and penalties.
• Represented a real estate agent before the Advisory Group Division of the IRS resulting in a discharge of federal tax lien, avoidance of foreclosure of real property, consummation of a short sale, transfer of clean title and protection of real estate agents license and future career pursuits.
• Represented a manufacturer in a Pennsylvania sales and use tax audit and subsequently at the appeals level, resulting in a reduction in the tax assessment by more than $250,000, followed by an application for abatement with Pennsylvania Board of Finance and Revenue which resulted in abatement of penalties in excess of $235,000 for a combined savings to the client of $485,000.
• Represented an officer of a Philadelphia-area construction company and obtained decision dismissing, with prejudice, a $1.5 million responsible officer/trust-fund recovery penalty action brought by the Philadelphia Revenue Department against various officers of the company for unpaid wages and business-privilege taxes.
• Represented a retiree before the Collection Division of the IRS and arranged the elimination of about $35,000 in income tax resulting from an erroneous assessment made by the IRS.
• Represented a golf course before the Collection Division of the IRS and negotiated the abatement of a civil tax penalty of more than $14,000 as a result of failure to file required tax returns.
• Represented a decedent before the Examination Division of the IRS resulting in an income tax savings of more than $100,000.
• Represented a supplier of communication systems and services before the Examination Division of the IRS and secured a "no change" income tax report.
• Represented a lawyer before the New York Department of Finance and Revenue resulting in a "no change" income tax report.
• Represented a college professor of one of the most prestigious universities in Pennsylvania before the Examination Division of the IRS resulting in a "no change" income tax report.
• Represented a regional law firm before the City of Philadelphia resulting in the reduction of a tax deficiency assessment from $250,000 to $50,000.
• Representation of a liable spouse before the Criminal Investigation Division of the IRS, avoided criminal prosecution, significant reduction of tax liability, submission and acceptance by IRS of Offer in Compromise.
• Represented a seller of sports memorabilia before the Examination Division of the IRS and secured a "no change" income tax report.
• Represented a client before IRS and successfully compromised a tax liability of more than $4 million for less than $350,000.
• Represented an international law firm before the City of New York Tax Appeals Tribunal resulting in a reduction in New York City unincorporated business tax from $230,000 to $25,000.
• Represented an international law firm before the Chicago Department of Revenue and secured a "no change" sales tax report.
• Represented a lawyer before the Appeals Division of the IRS and negotiated a compromise of a $2 million tax liability for $110,000 and a similar compromise with the Commonwealth of Pennsylvania whereby a $120,000 liability was settled for $20,000.
• Represented a physician before the Collection Division of the IRS and arranged the release of levies, a reduction in assessed tax by approximately $400,000 and elimination of interest and penalties of approximately $50,000 after the discovery of an IRS calculation error.
• Represented a personal financial planner before the Collection Division of the IRS and negotiated a compromise of a significant federal income tax liability resulting in a savings of more than $700,000.
• Represented a partner of a real estate development company before the Collection Division of the IRS and successfully convinced the IRS that the partner was not a responsible officer resulting in elimination of more than $400,000 in trust fund tax assessments and related interest and penalty.

• Represented a medical practice and its principal physician in a dispute with one of the largest insurance carriers and provider networks in New Jersey in connection with a health insurance reimbursements dispute in excess of $800,000. The dispute alleged that the practice submitted claims that falsely represented the physicians at the practice providing services for the carrier’s insureds and that such physicians were not credentialed with the carrier to provide such services. The matter was successfully resolved at a 95% concession by the carrier.
• Conducted a forensic examination for one of the largest international shipping and transportation companies, including performing asset investigation services identifying hidden assets in a $1.5 million vendor fraud matter. Also performed an extensive Successor Liability, Alter Ego and Piercing of the Corporate Veil analysis in an effort to assist in recovery.
• Represented a spouse in a marital dispute and conducted asset locator services identifying over $100 million in hidden assets resulting in a significant marital settlement.
• Assisted the Office of Federal Housing Enterprise Oversight (OFHEO) in conducting its extensive and complex Special Examination of Fannie Mae's manipulation of accounting and earnings to trigger bonuses for senior executives. The examination resulted in a comprehensive report of more than 340 pages and an agreement by Fannie Mae to pay $400 million in penalties and enter into a significant plan of remediation.
• Performed a damage analysis and provided an in depth analysis of an opposing expert's damage report in a trademark infringement case related to the unlicensed distribution of certain auto parts resulting in favorable result to client.
• Conducted a forensic examination for an international asset management organization, including interviews, and identified employee fraud and resulting economic damages in excess of $100,000.
• Represented a spouse in a marital dissolution and prepared a comprehensive net worth analysis and business valuation used to secure a favorable settlement.
• Represented an estate in a wrongful death matter, conducted in-depth interviews, prepared extensive damage calculations, and assisted counsel in obtaining favorable result for the client.
• Developed extensive damage models and performed complex damage analysis calculations which were utilized by a Director and Officer insurance carrier in defending a claim arising from a securities fraud litigation matter involving a national telecommunications company resulting in favorable outcome for client.
• Prepared an extensive analysis of reasonable salaries and lost profits in a class action litigation matter involving an international chemical company resulting in favorable decision for the client.
• Prepared a report for a national insurance company quantifying the relative and absolute damage exposure faced by Underwriter Defendants following an alleged accounting fraud of an international energy company in a class action securities matter.
• Conducted a suitability analysis and alternative investment strategy analysis and provided a report regarding the damages sustained by a plaintiff as a result of alleged professional negligence by a broker resulting in favorable decision for client.
• Performed a compliance audit for a special committee of a large real estate investment trust to determine amounts due former shareholders under various agreements.
• Performed an extensive successor liability analysis for an automobile dealership resulting in a favorable decision for the client.
• Prepared an extensive shareholder oppression claim analysis including damage assessment in connection with an international technology company resulting in a favorable settlement for shareholders.
• Performed a comprehensive forensic investigation of employee fraud in a retail business resulting in a favorable result for the client.
• Prepared a comprehensive damage analysis in connection with an employee stock option plan, including alternative investment analyses and analysis of fiduciary breaches resulting in a favorable outcome for client.
• Developed complex damage models to measure lost profits incurred by a regional brokerage firm as a result of published defamatory statements resulting in a favorable outcome for client.
• Prepared a comprehensive damage analysis for a national food retail and distribution company and served as a consultant to the experts for counsel resulting in a favorable outcome for client.

• Conducted an improvement study for a regional medical services provider and prepared a report addressing corporate strategy, underlying systems and processes including cash management, receivables, collections and OSHA compliance. Post implementation, client enjoyed significant cost savings and increased profits.
• Conducted an analysis of application of generally accepted accounting principles for a governmental entity related to capital v. operating lease reporting resulting in a favorable leasing arrangement for client.
• Conducted an improvement study for a facilities management company resulting in the implementation of recommended changes to cash and receivable management systems and improved internal controls.
• Served as entrusted agent to an international real estate developer with more than $50 million of escrow funds under management.
• Conducted a license agreement and systems review of an international medical products manufacturer resulting in the identification of unpaid and underpaid royalty fees of approximately $300,000.
• Analyzed various financial reporting models under generally accepted accounting principles for an international technology company in support of counsel recommendations in due diligence proceedings related to an international acquisition.
• Served as court appointed accountant to the bankruptcy trustee in a securities firm bankruptcy matter and prepared a comprehensive accounting and managed the liquidation disbursement process for the trustee.
• Performed a policy and procedure review for a law firm, including analysis of office procedures, cash management, collections and financial reporting resulting in increased operational efficiency and profitability.
• Prepared a comprehensive analysis of the reasonableness of the salaries of employees and shareholders of a physician practice based on standards established by the IRS and courts.