U.S. OF AMERICA, INTERNAL REVENUE SERVICE V. POLARDI
This matter was before the United States Tax Court in which this firm represented the defendant. The Defendant was previously married to the Chief of Police of a nearby city who had been convicted of tax evasion and fraud. Since the defendant was then his wife and had executed joint returns with the former Chief, the I.R.S., through appeals, sought to inculpate the spouse, represented by the firm, as jointly and severally liable for the aforesaid tax liability which was in the mid-six (6) figures. After extensive negotiations and discovery and submission of briefs, the I.R.S. conceded the case on the eve of trial so that the firm's client prevailed based upon the defense provided by the Innocent Spouse Provisions of the Internal Revenue Code.