Frantz Ward’s Tax Practice Group advises on a broad scope of tax matters and represents clients in disputes with the Internal Revenue Service, Ohio Department of Revenue, Ohio Attorney General, and other taxing authorities. Our experienced team guides clients through audits, administrative proceedings, and judicial proceedings.
We help clients navigate complex tax issues and achieve optimal results in matters such as:
- Individual and entity-level income tax
- Minimizing liability in estate planning and gift taxes
- Excise tax
- Federal tax litigation
- Tax debt resolution
- Tax analysis of proposed transactions
- Executive compensation
- Pension programs and other employee benefit plans
- Corporate, partnership, and limited liability company organization, reorganization, and liquidation
- Tax implications of business asset transfers and real estate ownership
- Tax-free exchanges of real estate
Representative Matters
- Represented a medical professional who owned shares in both a professional company and an outpatient surgery center. The US Tax Court ruled in favor of the client, holding income from the outpatient surgery center income was passive (and could thus be offset by other passive losses), rejecting IRS arguments that the taxpayer had made an unauthorized change of accounting method, and despite the doctor being a general partner in the partnership that owned the surgery center.
- Represented a nonresident alien professional athlete before the US Tax Court in a landmark dispute with the IRS over the tax treatment and US vs. foreign sourcing of name, image, and likeness (NIL) endorsement fees. The US Tax Court allocated the income based on the relative value of the golfer’s NIL inside vs. outside the US, adopting the taxpayer’s approach and establishing a new case law precedent.
- Represents entities throughout the application for tax-exempt status under Section 501(c)(3) of the Internal Revenue Code.
- Handles and assists in the representation of individual and business clients in tax-related planning, including choice of entity, business succession, estate, charitable giving, exempt organizations, and controversy with the Internal Revenue Service.
