Current shareholder at Midgett & Preti PC with a practice focused on estate planning, probate and trust administration, IRS and state and local tax audit and tax collection cases, as well as individual and entity tax planning, asset protection and a variety of related transactional matters such as business succession planning, business entity start-ups, mergers, acquisitions, corporate re-organizations and tax planning for divorce.
I have extensive experience in drafting and implementing all types of basic and complex estate planning documents such as revocable trusts, irrevocable life insurance trusts (ILIT), grantor retained annuity trusts (GRAT), charitable remainder annuity and unirusts (CRAT and CRUT), charitable lead annuity and unitrusts (CLAT and CLUT), asset protection trusts, and dynasty trusts (or generation skipping transfer tax trusts). To compliment my planning practice, I assist clients with the administration of trusts and estates, whether through the probate process or in private trusts, and often serve as the executor and/or trustee for clients seeking long-term, professional trust management. To ensure my clients receive complete trust/estate administration services, I maintain an extensive tax compliance and preparation practice specializing in individual, gift, estate and trust income tax and preparation (Form 1040, 1041, 706 and 709), and trust and estate fiduciary accounting preparation.
A significant part of my tax practice is dedicated to representing individuals and businesses before the IRS, state, and local taxing authorities in tax disputes, audits, appeals and collection actions. The scope of my audit and examination defense practice covers the entire process, from the initial Information Document Request through audit, administrative hearings, appeals, and litigation if necessary. My tax collection practice helps clients by removing levies, garnishments and liens, amending and correcting previous tax returns, filing delinquent tax returns, negotiating with the IRS and state governments to establish payment plans, conducting Collection Due Process Hearings (CDP), and submitting Offers in Compromise (OIC) to settle taxpayer debts that cannot be repaid. I also assist taxpayers with resolving past non-compliance with Foreign Bank Account Reporting (FBAR) and voluntary disclosure, including use of the IRS offshore Voluntary Disclosure Program (OVDP), Streamlined Filing Compliance, Delinquent Submission Procedures and Quiet Disclosures.
Besides an attorney, I am a certified public accountant, and served in the U.S. Marine Corps as a member of Delta Co., 4th Light Armored Reconnaissance Battalion, 4th Marine Division.