Michael Sardar

Michael Sardar joined Kostelanetz & Fink, LLP in 2009. Mr. Sardar's practice focuses on all stages of civil and criminal tax controversies. He represents taxpayers before the Internal Revenue Service, state tax authorities, the Department of Justice, and local prosecutors. Mr. Sardar has vast experience representing clients making voluntary disclosures of unreported income to the Internal Revenue Service and state tax authorities.

Mr. Sardar has successfully represented scores of clients with unreported foreign assets who have repatriated over half a billion dollars of offshore assets through the IRS's Offshore Voluntary· Disclosure Program and the Streamlined Compliance Procedures. Mr. Sardar also represents taxpayers in New York State and City residency audits and investigations. Mr. Sardar is the Vice-Chair of the New York County Lawyers' Association (NYC LA) Taxation Committee, member of the Committee on Personal Income Taxation, New York City Bar Association, as well as Co-Chair of the Sub-Committee on Offshore Enforcement of the ABA Committee on Civil and Criminal Tax Penalties. Michael lectures frequently on tax controversy issues including foreign asset reporting and non compliance.

Representative Matters

  • Mr. Sardar secured a favorable non-jail sentence for a client facing federal criminal charges relating to undeclared foreign bank accounts.

  • Mr. Sardar convinced the New York County District Attorney's Office to abandon a criminal investigation of his client and successfully resolved the case in a civil manner.

  • Mr. Sardar Successfully represented alleged "responsible officer" taxpayer assessed large penalties for unpaid withholding tax, entire assessment was canceled despite the fact that all of taxpayer's statutory and regulatory remedies were time-barred.

  • Mr. Sardar represented a wife in innocent spouse proceedings before the IRS and NYS, she was deemed an innocent spouse as to all taxes previously assessed.

  • Mr. Sardar secured credit for $3 million in taxes withheld on taxpayer's foreign account. which IRS had previously denied.

  • Mr. Sardar successfully sought the return of cash seized from his client by U.S. Customs and Border Protection.

  • Mr. Sardar successfully represented taxpayers in connection with a criminal referral to the Criminal Investigation Division (CI) of the IRS and resolved the matter civilly with no significant penalties against the taxpayers.

  • Mr. Sardar represented a taxpayer in connection with an IRS criminal investigation which had been initiated by a whistle blower who was cooperating with the IRS. Mr. Sardar convinced the IRS Criminal Investigation Division to terminate the investigation with no charges against his client.

Prior to joining Kostelanetz & Fink, Mr. Sardar was a tax associate in the New York office of Heller Ehrman, LLP, where his practice focused on federal and state transactional tax matters. While at Heller Ehrman, Mr. Sardar also advised many nonprofit organizations on federal and state tax issues including general tax exemption and Unrelated Business Income Tax (UBIT). Mr. Sardar received his B.B.A., summa cum /aude, from Baruch College in 2004, and his J.D. in 2007 from Cornell University Law School.