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ROSTER

cciraolo@rosenbergmartin.com

Recent Cases

• Monk v. Commissioner, T.C. Memo. 2008-64 (March 17, 2008) (successfully argued to U.S. Tax Court that Mr. Monk did not own a bar in Baltimore, Maryland, despite the fact that Mr. Monk reported the business on his personal tax returns, and therefore was not responsible for unreported income, unsubstantiated expenses or penalties).
• Gathers v. Commissioner, Docket No. 1257-07 L (U.S. Tax Court) (May, 2008) (successfully persuaded the IRS to consent to a remand of a collection case back to the Appeals Division for further consideration).
• Alternatives Unlimited v. Commissioner, Docket No. 1351-07 L (U.S. Tax Court) (May, 2008) (challenged the IRS Notice of Determination sustaining intent to levy for failure to properly consider pending penalty abatement claim; IRS abated failure to deposit and failure to pay employment tax penalties in excess of $500,000, allowing taxpayer to pay remaining balance in full).
• Beatty v. Commissioner, T.C. Memo. 2007-167 (June 27, 2007) (successfully persuaded the IRS to grant innocent spouse relief to Mrs. Beatty for each year at issue; tax, penalties and interest exceeded $725,000).
• Mohunlall v. Intercoastal Investment Trust, Ld., Docket No. 03-C-06-003938 (Circuit Court for Baltimore County) (June, 2007) (successfully defended claims of intentional misrepresentation, concealment and nondisclosure, constructive fraud and breach of contract against the defendants, obtaining a stipulated dismissal with prejudice).
• Bainbridge v. Commissioner, Docket No. 12819-05 (U.S. Tax Court) (July, 2006) (successfully challenged proposed deficiencies and penalties and persuaded the IRS to accept taxpayer’s returns as filed)
• Suddreth v. Commissioner, Docket No. 19342-03 (U.S. Tax Court) (June, 2006) (successfully persuaded the IRS to grant innocent spouse relief to Mrs. Suddreth for each year at issue).
• Taylor v. Commissioner, Docket No. 11480-03 (U.S. Tax Court) (March, 2004) (successfully persuaded the IRS to grant innocent spouse relief to Mrs. Taylor for each year at issue).
• Mosca v. Commissioner, Docket No. 11411-00 (U.S. Tax Court) (November, 2001) (successfully persuaded the IRS to grant innocent spouse relief to Mrs. Mosca for each year at issue)
• Rose v. Commissioner, Docket No. 005267-98 (U.S. Tax Court) (December, 1998) (successfully persuaded the IRS to concede one year at issue in its entirety, significantly reduce proposed deficiencies on the remaining tax years, and concede all fraud penalties).
• Smith v. Commissioner, Docket No. 001847-98 (U.S. Tax Court) (December, 1998) (successfully challenged deficiencies and penalties proposed and persuaded the IRS to accept the Smiths’ tax returns as filed).

Caroline D. Ciraolo

Partner

Publications

• The Morning After - What You Need to Know About FBAR and International Information Returns Including Defending Against and Litigating the Penalties
• (November 2009)
• Sales and Use Tax in Maryland, Lorman Education Services (5/29/2008)
• Civil and Criminal Tax Penalties: Important Developments - Criminal (January 2007; May 2007; September 2007; January 2008)
• Facts & Findings: Criminal Tax Cases (September 2007)
• Tax Talk: Innocent Spouse Relief - Coming Full Circle (Almost...) (March, 2007)
• When Business Becomes Personal - Personal Liability for Federal and Maryland State Taxes (November/December 2006)
• Attaching Property Held As Tenancy by the Entirety: The Response to Craft (January 2004)

Recent Developments

• Caroline D. Ciraolo was a panelist at the ABA Tax Section meeting in Chicago on September 26, 2009 regarding the defense and litigation of penalties associated with Foreign Bank Account Reports and International Information Returns. TaxAnalysts, a nonprofit publisher that provides the latest and most in-depth tax information,  cited Ms. Ciraolo's comments regarding the Internal Revenue Service's Offshore Voluntary Disclosure program in a September 29, 2009 article.  Click here to view the article. .
  
  
• Caroline D. Ciraolo was interviewed by The Baltimore Business Journal  regarding the Internal Revenue Service's Offshore Voluntary Disclosure program in a September 25, 2009 article.  Click here to view the article.
  
  
• Caroline D. Ciraolo was interviewed by Investment News, a primary source for financial advisors, regarding the Internal Revenue Service's Offshore Voluntary Disclosure program in an August 19, 2009 article.  Click here to view the article.
  
  
• Caroline D. Ciraolo was interviewed by Investment News, a primary source for financial advisors, regarding the Internal Revenue Service's Offshore Voluntary Disclosure program in an August 12, 2009 article.  Click here to view the article.

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