Caroline D. Ciraolo Representative Civil Matters

  • 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 substantially reducing proposed deficiency and penalties, and later successfully challenged the date on which the IRS posted a restitution payment, resulting in a significant)
  • 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)
  • Bresnahan v. Commissioner, Docket No. 29013-11, U.S. Tax Court (February 15, 2012) (successfully challenged proposed tax deficiency and fraud penalty).
  • Mavroulis v. Commissioner, Docket No. 15320-11, U.S. Tax Court (February 8, 2012) (persuaded the IRS to grant innocent spouse relief)
  • Okiebisu v. Commissioner, Docket No. 23245-11, U.S. Tax Court (January 31, 2012) (successfully challenged proposed fraud penalty)
  • 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 and accuracy-related penalty)
  • Lokey v. Commissioner, Docket No. 26865-09, U.S. Tax Court (June 15, 2011) (persuaded the IRS to grant innocent spouse relief)
  • Grady, et al. v. Commissioner, Docket No. 25741-10S, U.S. Tax Court (June 14, 2011) (successfully challenged accuracy-related penalty)
  • 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 and penalties)
  • Haddock v. Commissioner, Docket No. 25759-08, U.S. Tax Court (June, 2010) (successfully challenged proposed tax deficiencies and fraud penalties, resulting in substantial reductions and an overpayment)