Caroline D. Ciraolo Representative Matters (Civil)

  • In re Interstate Subpoena for Custodian of Records, Misc. Petition No. 29618M, Circuit Court for Montgomery County, MD (March 27, 2014) (successfully intervened in and obtained a protective order in response to a grand jury subpoena for a client’s records in the possession of an accountant)
  • United States v. Stahlnecker, Case No. 1:13-cv-01050-MJG, U.S. District Court for the District of Maryland (February 25, 2014) (successfully negotiated a settlement of a suit to reduce a federal tax lien to judgment, resulting in a reduction of assessed trust fund recovery penalties by approximately $400,000).
  • Signature Flight Support Corporation v. Supervisor of Assessments for Anne Arundel County, Case No. 13-MI-AA-0579 (1-2), Maryland Tax Court (January 22, 2014) (successfully challenged the denial by the State Department of Assessment and Taxation and the Property Tax Assessment Appeals Board for Anne Arundel County (“PTAAB”) of an application for exemption from property tax on substantial improvements at the Thurgood Marshall Baltimore Washington International Airport, establishing that client was exempt as lessee of property owned by the State and used for a concession at a public airport)
  • State of New York v. John Doe, Case No. C-13-179578, Circuit Court for Anne Arundel County, MD (November 8, 2013) (successfully intervened in and negotiated a dismissal of an action to enforce a grand jury subpoena for a client’s records in the possession of an accountant)
  • United States v. Gill, Case No. 12-cv-03813-RDB, U.S. District Court for the District of Maryland (June 13, 2013) (successfully negotiated a settlement of an action to reduce a federal tax lien to judgment, and a dismissal of a complaint to foreclose property)
  • Kareri v. Commissioner, Docket No. 16057-10, U.S. Tax Court (September 18, 2012) (negotiated stipulated Decision reducing proposed deficiency by more than $225,000 and reducing proposed penalty by more than $168,000 for tax years 2000 through 2003, and later successfully challenged the date on which the IRS posted a restitution payment, resulting in a refund of more than $138,000)
  • Sharabi v. Commissioner, Docket No. 8999-11, U.S. Tax Court (September 7, 2012) (successfully challenged proposed tax deficiency of $191,989, resulting in no tax or penalties due)
  • Annapolis Accommodations, Inc. v. Comptroller, Case No. 10-SU-OO-0606 (May 2, 2012) (successfully challenged Comptroller’s assessment of penalty and interest with respect to sales tax assessment)
  • Estate of Darrell L. Clark v. Commissioner, Docket No. 27590-11, U.S. Tax Court (April 9, 2012) (successfully challenged proposed tax deficiency of $110,923 and an accuracy-related penalty of $28,541, resulting in no tax or penalties due)
  • Bresnahan v. Commissioner, Docket No. 29013-11, U.S. Tax Court (February 15, 2012) (successfully challenged proposed tax deficiency in the amount of $337,288 and a fraud penalty in the amount of $161,483.25, resulting in a final deficiency in the amount of $71,382, an accuracy-related penalty in the amount of $14,276.40).
  • Mavroulis v. Commissioner, Docket No. 15320-11, U.S. Tax Court (February 8, 2012) (persuaded the IRS to grant innocent spouse relief for the full balance due for tax year 2003)
  • Okiebisu v. Commissioner, Docket No. 23245-11, U.S. Tax Court (January 31, 2012) (successfully challenged proposed fraud penalty in the amount of $96,211.50)
  • Edwards v. Commissioner, Docket No. 13315-10, U.S. Tax Court (January 18, 2012) (successfully argued insolvency exception to cancellation of indebtedness income, resulting in no deficiency)
  • Shrader v. Commissioner, Docket No. 26665-10, U.S. Tax Court (August 9, 2011) (successfully challenged proposed tax deficiency of $20,144 and an accuracy-related penalty of $4,029, resulting in no tax or penalties due)
  • Lokey v. Commissioner, Docket No. 26865-09, U.S. Tax Court (June 15, 2011) (persuaded the IRS to grant innocent spouse relief for the full balance due for tax year 2005)
  • Grady, et al. v. Commissioner, Docket No. 25741-10S, U.S. Tax Court (June 14, 2011) (successfully challenged accuracy-related penalty, resulting in no penalty due)
  • Solomon v. Commissioner, Docket No. 12763-10L, U.S. Tax Court (February, 2011) (successfully opposed IRS motion for summary judgment in response to petition for redetermination of levy action under IRC  6330)
  • Samaco v. Commissioner, Abiog v. Commissioner and Ucol-Cobaria v. Commissioner, Docket Nos. 14885-09S, 14886-09S and 14887-09S, U.S. Tax Court (January, 2011) (successfully challenged accuracy-related penalties proposed against Filipino teachers who failed to report their teaching income earned from Baltimore City Public School System)
  • Gunther v. Commissioner, Docket No. 26204-08, U.S. Tax Court (November, 2010) (successfully challenged proposed tax deficiencies in the amount of $120,083 and penalties in the amount of $46,603.50, resulting in final deficiencies in the amount of $2,530 and penalties in the amount of $52.50)
  • Haddock v. Commissioner, Docket No. 25759-08, U.S. Tax Court (June, 2010) (successfully challenged proposed tax deficiencies for two tax years in the aggregate amount of $674,908 and fraud penalties in the aggregate amount of $479,254, resulting in a final deficiency for one year in the amount of $67,786, a negligence penalty in the amount of $9,635.20 and an overpayment in the amount of $21,824)