- Cummins & White, LLP, successfully represented a media manufacturing firm in an IRS audit, appeal, and court case involving the proper accrual of royalties paid for using patented technology in the duplication of DVDs and CDs.
- Cummins & White’s in-depth knowledge of IRS administrative and Tax Court procedures, as well as substantive rules regarding deductions by accrual basis taxpayers helped the Client avoid a $1 million tax bill.
- The firm also helped the Client avoid future exposure by filing a case in Tax Court. As part of the proceedings, the IRS issued a final letter of determination, effectively exempting the Client from repeat audits of the same tax years.
- The two-year process involved sorting through a significant amount of documentation—much of it in disarray—that accumulated when the Client acquired a similar firm, which also paid royalties as part of technology license agreements.