1. Corporate Attorney NY Manhattan Corporate Tax Challenge
The investigation revealed that the client’s corporate account received deposits exceeding USD 1.6 million.
The tax authority presumed these amounts were unreported corporate revenue.
Our analysis established that the deposits originated from criminal misuse of the account.
The core issue was whether the corporation could be legally treated as having earned taxable income despite being merely a nominal account holder.
Our approach focused on demonstrating economic reality, emphasizing that the corporation had no operational activity and no service or product generation.
Criminal proceeds do not constitute taxable corporate income.
Police reports and investigatory files showed the account was used as a conduit by fraudulent brokers.
Under NY law, taxation depends on actual earning activity, not on the presence of deposits into an account.
We organized evidentiary records to prove the absence of business purpose and the presence of third-party control.
Identifying the True Beneficiary of Criminal Proceeds
The tax authority argued that the client was the “real operator.” Our team countered this by proving that the corporation lacked employees, contracts, revenue agreements, and operational structure.
By analyzing transaction flows, we showed the funds were instantly transferred out by criminal actors.
The legal burden of establishing true economic ownership fell on the authorities, not the victim.
This framework supported our argument that the client was not the beneficiary of the deposits.
2. Corporate Attorney NY : Taxpayer Defense Strategy
We structured the defense to align with NY Department of Taxation and Finance standards, focusing on statutory income definitions and administrative fairness.
Our position emphasized that tax assessments must be based on evidence, not presumptions arising solely from account activity.
We submitted police records of voice phishing, messenger fraud, and electronic fraud investigations confirming misuse of the account.
These records aligned with NY’s recognition that misuse victims cannot be held responsible for criminal deposits.
Our team presented sworn statements and documentation supporting the lack of gain or benefit.
This evidence reframed the client not as a violator but as a victim requiring legal protection.
3. Corporate Attorney NY : Legal Analysis on Assessment Procedure
The tax authority used an estimated assessment method, asserting inadequate records. We showed this method was improperly applied under NY law.
Estimated assessments require proof that legitimate income cannot be determined from available documentation, which was not the case here.
Challenging the Improper Estimated Assessment
We demonstrated that the 1.6 million USD sum could not be “estimated” as revenue because it was proven criminal in origin.
Even if records were incomplete, tax law prohibits attributing illegal deposits as taxable income when the taxpayer is not the economic beneficiary.
We highlighted NY precedents requiring assessments to reflect true income rather than assumed income.
This argument undermined the legal basis of the tax authority’s determination.
And, we argued the deposits should be classified as non-income unauthorized deposits.
Classifying them properly under NY regulations rendered the assessment invalid.
This supported our petition for cancellation of the proposed corporate tax liability.
4. Corporate Attorney NY : Administrative Review Outcome
Our submission to the administrative review panel resulted in a full cancellation of the tax authority’s proposed assessment.
The panel accepted our arguments that the corporation was not the true recipient of the funds and that the assessment violated NY’s standards for evidentiary taxation.
Confirmation of Non-Taxable Status of Misused Account Deposits
The panel concluded that:
This resulted in a complete cancellation of the USD 55,000 corporate tax assessment.
26 Nov, 2025
