About

Overview

Justin Hughes resolves tax issues for individuals and businesses. He has extensive experience as a CPA and also as a tax attorney. His experience allows him to efficiently and effectively assist clients in a variety of settings, including federal and state examinations, appeals, Tax Court, and all aspects of tax collections.

Over his career, he has helped individuals and businesses reduce their proposed income tax adjustments by millions of dollars in IRS examinations, Appeals, and Tax Court. He has helped a number of taxpayers reduce or eliminate their existing tax debts through offers in compromise and other post-assessment procedures. In addition, he has helped taxpayers with significant tax debts enter into collection alternatives.

His goal is always first to understand a client’s situation and then determine the best solution for the client based upon their specific facts and circumstances. He always seeks to find an efficient way to help his clients minimize their current tax burden and manage their future tax risk.

Justin serves clients in Maryland and federal tax clients worldwide.

Practice Areas

Tax, Tax Controversy, Tax Planning

Admissions

• Attorney: Maryland, Pennsylvania, New York
• Certified Public Accountant: Maryland, Pennsylvania

Education

• LL.M. in Taxation – New York University School of Law – 2007
• J.D. – Case Western Reserve University School of Law – 2006
• B.S., Accounting – Pennsylvania State University – 1999

Representative Experience*

*Please note that each case is different and my past record is no assurance that I will be successful in reaching a favorable result in any future case.

• IRS CP2000 – Reduced proposed IRS adjustment based upon incomplete brokerage data on Forms 1099.
• IRS CP2000 – Eliminated proposed IRS adjustment based upon gross activity from cryptocurrency exchange reported to IRS on Form 1099-K.
• IRS Civil Examination – Assisted small Schedule C business receive a no-change letter from IRS after compliance research examination.
• IRS Civil Examination – After receipt of the draft examination report, assisted real estate broker to reduce the IRS’s proposed adjustments by more than $250,000
• IRS Civil Examination – After receipt of draft report, assisted client in Amazon retail business reduce proposed tax, penalties, and interest by approximately $800,000.
• IRS Civil Examination – Reached civil settlement in several eggshell examinations involving unreported income in excess of six figures.
• IRS Appeals – Successfully appealed Revenue Agent’s denial of real estate professional status.
• IRS Appeals – Successfully appealed proposed penalty for late filing of Form 3520.
• U.S. Tax Court – Obtained six figure reduction in proposed tax and penalties by challenging tax computations and lack of managerial penalty approval.
• IRS Offer in Compromise – Successfully reduced business owner’s tax debts (both individual income tax and TFRP) through Offer in Compromise.
• IRS Offer in Compromise – Successfully reduced business’s federal tax debt by seven figures through Offer in Compromise.
• IRS Appeals -Trust Fund Recovery Penalty – Successfully challenged assertion of TFRP against adult children for family businesses’ unpaid payroll tax.
• Federal Worker Classification Examination – After draft report was received, Utilized Fast Track Settlement program to reach favorable resolution based upon IRS’s Classification Settlement Program (CSP).
• Federal Information Return Penalties – Assisted client in successfully challenging proposed penalties on IRS Form 972CG regarding taxpayer identification number matching errors on Forms 1099-MISC.
• Maryland Personal Assessment – Successfully appealed Maryland Comptroller’s proposed personal assessment against executor & beneficiary of estate for decedent’s business’s tax debts.
• IRS Private Letter Ruling – Obtained ruling that amounts reported to taxpayer on Form 1099-C by employer’s pension plan were not includable in income due to prior inclusion of income.
• IRS Private Letter Ruling –  Obtained ruling granting waiver of 60-day rollover period for failed attempt to structure rollover and acquisition of real estate through self-directed IRA.
• IRS Levy Relief – Received partial refund of levy from account receivable due to IRS’s failure to allow necessary expenses, which caused an economic hardship.
• U.S. Tax Court – Reached favorable settlement with IRS counsel on partial deduction of of start-up expenses in excess of six figures.

Additional Professional Experience

• Of Counsel – Frost Law – Annapolis, MD – 2014 – Current
• Senior Manager – Deloitte Tax, LLP – M&A Transaction Services – New York, NY – 2008 to 2013
• Accountant – Fiore, Fedeli & Sndyer, P.C. – State College, PA – 1999 – 2003