Solving Tax Problems For Over 50 Years

John Tyler, alongside Mr. Rollins, successfully resolved a complex estate valuation case. The decedent and his spouse passed away simultaneously, leaving dozens of apartment complexes and single-family residences to the heir. The IRS challenged the estate’s reported valuations, demanding $9.4 million in taxes. Through skilled negotiation, Mr. Tyler and Mr. Rollins secured a settlement of approximately $300,000 in taxes and interest.

Mr. Tyler and Mr. Rollins successfully defended a taxpayer in a highly publicized “Son of BOSS” tax shelter case. American Boat is now the leading case establishing the use of a reasonable cause defense in tax shelters and has been cited extensively in both courts and scholarly articles. After an appeal by the United States, Mr. Tyler and Mr. Rollins again achieved a favorable outcome in the 7th Circuit Court of Appeals.

Mr. Tyler successfully defended the first docketed case before the Tax Court under Internal Revenue Code § 845 concerning reinsurance. The case was resolved in the taxpayer’s favor with no deficiencies found.

Mr. Tyler defended a tax-free reorganization in which taxpayers exchanged sixteen McDonald’s franchises for McDonald’s stock. This case remains a leading precedent for the continuity of interest requirement in tax-free reorganizations.