Chess Pieces on a Chessboard

Representative Engagements

  1. Taxpayer’s late husband opened an account at Bank Leumi, Israel during the Iranian Revolution of 1979. The account was never reported to U.S. authorities. Taxpayer’s husband passed away and Taxpayer began receiving letters from the bank providing that her foreign account information may be turned over to the IRS.
  2. Result: Ben-Cohen Law Firm represented Taxpayer in the Offshore Voluntary Disclosure Program. Pedram Ben-Cohen negotiated with the IRS Agent and IRS Technical Advisor to reduce Taxpayer’s offshore penalty from 25% to 5%.

  3. A successful dentist was under audit by the IRS. The dentist substantially underreported the income from his dental practice over a period of years. Taxpayer had huge unexplained deposits in his bank accounts that he did not properly report as income on his tax return. This was a classic eggshell audit.
  4. Result: Ben-Cohen Law Firm represented the dentist during the examination. Pedram Ben-Cohen (1) prevented the audit from spreading to earlier and subsequent years, (2) convinced the agent not to refer the case to IRS Criminal Investigation, and (3) closed the audit without assessment of civil fraud penalties.

  5. A prominent Texas businessman was served with a subpoena in connection with a criminal investigation being conducted into Taxpayer’s foreign account at Credit Suisse, Switzerland.
  6. Result: Ben-Cohen Law Firm represented Taxpayer during the criminal investigation and responded to the subpoena. Pedram Ben-Cohen convinced the DOJ attorney handling the investigation to close the investigation and decline prosecution.

  7. Taxpayer owned a secret foreign account at UBS, Switzerland. Taxpayer received letters from the bank providing that Taxpayer’s account information may be turned over to the IRS.
  8. Result: Ben-Cohen Law Firm advised Taxpayer to file amended returns and delinquent FBARs (a quiet disclosure). Subsequently, Taxpayer was audited by the IRS and Pedram Ben-Cohen closed the examination with no FBAR penalties assessed.

  9. The accountant of a successful Los Angeles based real estate partnership mistakenly included a foreign person as a 10% partner of the partnership. In reality, the real estate partnership never had any foreign partners and it was owned 100% by U.S. persons. The IRS began levying the rental income of the real estate partnership for alleged withholding taxes owed on the foreign partner’s share of partnership income.
  10. Result: Ben-Cohen Law Firm represented the real estate partnership during the collection dispute. Pedram Ben-Cohen worked with the local Taxpayer Advocate to (1) immediately release the levy, (2) fully refund the taxes (plus interest) incorrectly assessed against the partnership, and (3) correct IRS records to reflect that the partnership does not have any foreign partners.

  11. Taxpayer participated in his employer’s retirement plan. Taxpayer’s employer was acquired by another company, at which time, the employer’s retirement plan was terminated, and Taxpayer received a distribution check representing his retirement savings. In order to exempt the distribution from being subject to tax, Taxpayer was required to rollover his distribution check into another retirement account within 60 days of receiving the check. Taxpayer did not timely rollover the distribution check and received notice from the IRS that his entire retirement savings was being taxed.
  12. Result: Ben-Cohen Law Firm represented Taxpayer during the correspondence audit. Subsequently, Taxpayer received a notice of deficiency. Pedram Ben-Cohen filed a Tax Court Petition and concurrently sought a ruling from the IRS waiving the 60-day rollover requirement. Pedram Ben-Cohen was successful in obtaining the ruling and Taxpayer’s retirement savings was not taxed.

  13. Taxpayers were U.S. citizens of Greek descent who established residency in Greece. In Greece, Taxpayers established companies to manufacture and sell mountain sports equipment and apparel. Taxpayers owned several foreign accounts in Greece with high balances. Taxpayers, on the advice of another law firm, entered the Offshore Voluntary Disclosure Program. Subsequently, Taxpayers were kicked out of the Offshore Voluntary Disclosure Program because their attorneys did not cooperate with the Revenue Agent assigned to Taxpayers’ case.
  14. Result: Taxpayers engaged the Ben-Cohen Law Firm to represent them in connection with the examination of Taxpayers’ foreign accounts. Pedram Ben-Cohen closed the examination with no FBAR penalties assessed.

  15. Taxpayers, husband and wife, were in the middle of a divorce, and the IRS audited their tax returns. Husband was a musician and his income was reported on IRS Form Schedule C (Profit or Loss From Business). Wife was a W-2 employee and properly reported all of her wage income. The IRS Agent proposed significant adjustments to Taxpayers' tax return. All the adjustments related to Husband's music business.
  16. Result: Wife engaged the Ben-Cohen Law Firm to represent her in an innocent spouse claim. Pedram Ben-Cohen filed an administrative innocent spouse claim with the IRS. The claim was denied. Subsequently, Mr. Ben-Cohen appealed the innocent spouse claim to IRS Appeals. IRS Appeals granted wife partial innocent spouse relief. Finally, Mr. Ben-Cohen filed a petition with the United States Tax Court and the IRS granted wife's innocent spouse claim in full.

Client Reviews
I approached Mr. Ben-Cohen regarding a pending case with the State of California and my small business. During a time that was quite stressful, I found Mr. Ben-Cohen to be the perfect person to represent me and my company. He communicated with me in clear terms so that I understood everything that was taking place in a timely manner. He treated my situation with the type of candor you only find in a consummate professional and successfully negotiated a deal with the State of California that far exceeded my expectations. I found him to be kind, efficient, sensitive and nothing short of brilliant. I consider myself fortunate to have met him and highly recommend his services. I will not hesitate to use his firm in the future should a need arise.
★★★★★
I am an international tax advisor and have worked with Pedram on more than a dozen difficult and challenging cases. Pedram's clients and fellow advisors highly respect him because he has an uncanny ability to quickly identify and work diligently to resolve his clients' issues. Pedram is pragmatic in his approach. He is transparent with his clients and dedicated to getting to a fair and reasonable outcome. I have attended an IRS Appeals conference with Pedram and would want no other attorney on my side. Pedram is extremely passionate in his work and representing his clients. He is also enjoyable to work with and develops very good relationships with his clients and fellow advisors. I highly recommend Pedram for any tax controversy work. Avvo, Curt
★★★★★
Top Drawer Tax Fraud Lawyer. Pedram got me out a CI jam I thought I would not resolve. He is also fair and reasonable with his billing. I interviewed 4 top Tax Fraud Lawyers in LA and went with Pedram...Glad I did! Google, Michael Jeppson
★★★★★
Pedram Ben-Cohen at Ben-Cohen Law Firm, PLC is one of the most incredible, creative, and caring attorneys I have ever dealt with. He gave us hope but also gave us the reality and worst case scenario. He fought for us tooth and nail. The attention and time Pedram put into the case was like no other. He charged us more than fair and was very reasonable in every aspect. He is not the kind of attorney that charges for every minute. I liked him very much not only as an attorney but as a person because he is very honest, is true to his integrity, and is dedicated to his clients. He loves what he does and has the passion to protect and defend his clients, which totally shows in his work and our outcome. We originally hired another attorney from a famous firm who basically did not give us much hope on our case . That is when we came to Pedram who won our case in a short amount of time and got us the outcome we were looking for. Because of Pedram and his creativeness, willingness, and dedication, he got us our favorable outcome. He is our go to attorney for sure, without a doubt. Avvo, Anonymous
★★★★★
A few years ago I had a major tax problem and I was looking for the right professional tax lawyer. I interviewed at least five experts and all of them were very professional. I am very picky. When I met Mr. Pedram Ben-Cohen, it took me no more than five minutes to decide that he was the one, and I was absolutely right with my intuition. He is very professional, knowledgeable, smart, and knows his job perfectly. In addition to all of his professional skills, as a person he is very friendly, pleasant, ready to help, and took care of me like I was his own family. I referred and recommended him to friends and family with tax problems and will continue to do so warmly to anyone. I know that he is able and will do his job the best way for his clients. He is my personal tax lawyer and expert and will remain so. Google, Shlomo Kattan
★★★★★
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