Elizabeth Prehn

Criminal Tax & Government Investigations

• Representation of physician charged with embezzlement and tax evasion: negotiated plea to one count.
• IRS-CI investigation of stage director for tax evasion: obtained DOJ declination.
• IRS-CI investigation of medical practice: secured government declination.
• Representation in CA criminal prosecution for payroll and insurance fraud: client (attorney) pled to a misdemeanor, while co-owners pled to felonies.
• Defended individual in FBAR and tax evasion case: resolved with two-count plea; spouse and business uncharged.
• Represented tech employee at trial for tax evasion; Convicted
• Grand jury investigation of business owner: matter declined for prosecution.
• Witness Representation in DC Solar prosecution before FBI and various creditor examinations;
• Witness Representation before IRS CI and US Attorney interviews

Co-counsel Services

• Provide tax analysis and opinion to criminal defense counsel
• Provide tax procedural opinion and navigation to criminal defense counsel
• Provide tax analysis to civil counsel for partnership dissolution
• Assist criminal counsel with post-sentencing financial packages and criminal restitution matters.

Civil Tax Controversy & Litigation

• Litigated Tax Court cases involving hobby loss rules, unfiled returns, and audit disputes.
• U.S. Court of Federal Claims: FBAR-related litigation.
• Successfully defended numerous IRS and FTB audits for real estate investors, high-income earners, and closely held entities, including no-change results in ERC and real estate-based audits.
• Hundreds of clients with unfiled tax returns successfully brought into compliance and penalties minimized where possible
• IRS and State Penalty Abatements.
• Offshore bank account and asset holder representation

Business & Nonprofit Matters

• Formation and ongoing representation of corporations, partnerships, and nonprofit organizations.
• Business tort and breach of contract litigation.
• Partnership dissolution with complex tax overlays.
• Entity revivor and cleanup matters with the State of California.

Trusts, Estates & Elder Law

• Prepare customized estate plans for individuals and families with U.S. and international assets.
• Represent trustees and beneficiaries in multimillion-dollar trust administrations.
• Defense of trustees in contested trust administrations and elder financial abuse cases.
• Beneficiary representation in estates valued at $13 million and $5 million, respectively.
• Probate and elder abuse claims involving attorney malpractice and fiduciary negligence.

Entertainment & Music Industry

• Formation and ongoing legal counsel to a music label with international distribution.
• Provided tax opinion in a complex partnership dissolution involving a music group with over 35 million records sold worldwide.
• Secured return of masters and intellectual property rights for a recording artist in a breach of contract matter with former management.
• Defended music business owner in IRS Tax Court litigation over business expense deductions.
• Represented artists with unfiled tax returns, tax levies, and federal/state collection matters.