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Allison D. H. Soares, JD, M.B.A., LL.M

Partner

Ms. Soares is a Senior Associate Attorney in our Firm. As a lawyer, she has representative experience defending individuals and entities before the Internal Revenue Services (IRS), Franchise Tax Board (FTB), Employment Development Department (EDD), and State Board of Equalization (SBOE).

Prior to joining our firm, Ms. Soares was an associate attorney for four years with a prominent law firm located in North San Diego County, where she advised an array of clients on complex business transactions and developed an in-depth knowledge of corporate, contract, and tax law. She provided information to clients regarding avoidance or resolution of problems with federal, state, and local taxing authorities and also performed various tax-based calculations as well as tax related research to ensure compliance with state, federal, and international law. Concurrent with this position, she also assisted a tax, accounting, and consulting firm with reviewing tax returns and conducting tax planning and research for individuals, small businesses, and multi-national corporations. Additionally, she researched and analyzed complex issues surrounding the processes and systems of organizations and ensured the implementation of the firm’s endorsed strategic plan, system, and organizational recommendations.

Ms. Soares was raised in Sun Prairie, Wisconsin. She received a Bachelor of Arts degree in Finance from the University of Wisconsin – Milwaukee. After graduation, Ms. Soares moved to Sao Paulo, Brazil to teach English to local business and medical professionals. After a year abroad, she moved back to San Diego and worked as an accountant at Physician Management Group, Inc. for three years. Her pursuit of a Law Degree then took her to Miami, Florida to attend St. Thomas University School of Law, where she excelled, ranked in the top twenty percent of her class, and was an Articles Editor for the Law Review.  After her first year of law school, she enrolled in the joint degree program to obtain both her Law Degree and M.B.A in Accounting with a specialization in Forensic Accounting.  Ms. Soares earned her Master of Laws in Taxation from the University of San Diego School of Law.

Ms. Soares also expanded on her previous accounting experience with several internships including a position at the United States Securities Exchange Commission assisting internal CPAs and attorneys with external investigations of alleged churning, revenue recognition errors, and a variety of securities fraud claims and an internship position with the Honorable William M. Hoeveler, Senior United States District Judge for the Southern District of Florida.  She later interned with the United States Attorney’s Office as a Certified Legal Intern, where she applied her accounting skills in extensive preparation on a multi-million dollar securities fraud case, leading to two days of testimony as a Summary Witness for the U.S. Government.

Representative Matters:

  • Represented taxpayer who had 30 million dollars in alter-ego liens erroneously assessed against it. Successfully appealed the filing of the liens and IRS withdrew all liens.
  • Appealed IRS Excise Tax Return disallowance of $1 million in exemptions on taxpayer’s return. Successfully appealed the claim which resulted in no tax due to IRS.
  • Tax preparer with $200,000 in penalties for “recklessly and willfully” preparing tax returns. Successfully reduced IRS penalties to $30,000.
  • Represented publicly traded company with over $114 Million Dollars in payroll tax liability, avoided successor liability claims, allowed company to continue operating, avoided all collection actions, while negotiating a payment plan.
  • Assisted client in multi-state fuel tax audit, saved client in over a $1million in sanctions and reduced overall liability by $600,000.
  • Defended a client in a criminal investigation based on allegedly structuring transactions, potentially filing of fraudulent income tax returns and failing to file IRS Form 8300. Resulted in a no arrests, Pre-Judicial Settlement Agreement and the government returned thousands of dollars of funds that were seized from the client’s bank account.
  • Represented clients in trust fund interviews and obtained favorable result by deflecting corporate trust fund liability for other corporate officers.
  • Defended multiple clients against IRS and Franchise Tax Board levies and garnishments which resulted in collection holds or successful collection alternatives for the benefit of the client
  • Represented a large north County Restaurant in their dispute over audit findings by the Board of Equalization; negotiated directly with the District Principal Auditor and saved client over half from their proposed taxable measure.
  • Represented client in disclosure of offshore bank accounts. Client faces hundreds of thousands of dollars in penalties and potential referral to Criminal Investigation Division (CID) of the IRS.
  • Represented tax preparer, who overstated business expenses, in a federal income tax audit. The IRS limited the audit to one tax year, no penalties were assessed and the balance due was less than $3,000.
  • Taxpayer received trust fund recovery penalty for his relationship to a business. Successfully abated full amount of $50,000 trust fund recovery penalty.
  • Represented multiple taxpayers with undisclosed foreign income and assisted them in entering the Offshore Voluntary Disclosure and the Streamlined Filing Compliance Procedures.
  • Performed tax return review to ensure compliance and avoid future conflicts with government agencies after audits or investigations.
  • Performed M&A work, including extensive due diligence, negotiations, contract review, financial statement review, and verification for a billion dollar UK parent company in the acquisition of 16 national companies. Maintained ongoing legal and tax representation for acquired companies.
  • Draft, review and revise contracts including employment, franchise (master/unit), asset purchase, stock sale, non-disclosure and promissory notes.
  • Strategized with clients to ascertain the best solution to their tax issues and assisted them in resolving their potential liabilities to adverse government action.
  • Reviewed and revised clients’ company handbooks, job descriptions and human resource policies.
  • Formation of entities tailored to meet clients’ specific needs including bylaws, operating agreement, EINs, 25102f and meeting minutes.
  • Created work process flows companywide to streamline the company’s processes and ensured successful conversion from excel spreadsheets to implementation of Macola accounting software.
  • Represented buyers and sellers on several business sales, stock purchases, and asset purchases; advised clients on a variety of transactional issues, and provided advice on post-closing tax implications.
  • Handled sales/use tax matters for a multi-million dollar distribution company; researched and implemented VAT tax for several foreign subsidiaries.
  • Obtained timely release of liens for individuals and businesses facing sanctions from the IRS.
  • Performed tax return review to ensure compliance and avoid future conflicts with government agencies after audits or investigations.
  • Conducted tax planning and tax research for individuals, small businesses, and multi-national corporations
  • Represented clients in SBOE sales and use tax audits and negotiated settlements of tax liabilities.
  • Placed several major clients, owing hundreds of thousands dollars, on reasonable and affordable payment plans.

Practice Areas:

  • Civil Tax Controversy
  • Corporate Law
  • Individual and Entity Tax Planning

Affiliations:

  • American Bar Association
  • California Bar Association, Business Law Section
  • San Diego County Bar Association Business Law Section & Taxation Law Section
  • Lawyer’s Club of San Diego
  • I Love a Clean San Diego Volunteer
  • North County Sunshine Rotary Club Member (inactive)
  • SDCBA Ask-A-Lawyer Volunteer 2014 & 2015

Awards:

  • San Diego Business Journal Best of the Bar 2015, 2016 and 2017
  • San Diego Business Journal Women Who Mean Business Finalist 2015
  • San Diego Metro Magazine Best Lawyer 2015
  • San Diego Daily Transcript Top Attorney Semifinalist 2015
  • San Diego Daily Transcript Top Young Attorney Finalist 2014
  • San Diego Daily Transcript Top Young Attorney Nominee 2013

Lecture Position:

  • San Diego State University, Adjunct Professor for Tax Procedures, Practice and Ethics at the Charles W. Lamden School of Accountancy (2014-Present)

Speaking Engagements:

  • Careers in Tax Law Panelist USD School of Law – Tax Law Society (2015)
  • International tax Compliance Issues and IRS audits Panelist, 2015 Mission Valley (2015)- CSEA San Diego Chapter
  • Appeals, Collections & Offshore Voluntary Disclosure Program, North County, Southern California Tax Consultants (2015)
  • IRS Audits, Collections and International Compliance Panelist at the Orange County California Society of Tax Consultants  (2015)
  • Appeals, Collections, OIC, & Offshore Voluntary Disclosure Program IRS & FTB Issues Panelist– Southern California Tax Consultants (2014)
  • 2013 Panelist IRS Audit Red Flags, California Audit & Collection Issues – CSEA San Diego Chapter

Admitted to Practice before the following Courts:

  • United States Tax Court
  • United States District Court for the Southern District
  • Supreme Court of the State of California

 

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