Mr. Marini successfully represented clients, at Appeals or in Court, in the following Tax Matters:
Over 50 - Large Case Audits (amount in dispute over $1MM)
Over 5 - Inter-Company Pricing Cases (Section 482)
Multiple Payroll Tax Collection Cases
Numerous Offer and Compromise Cases
Numerous Installment Payment Plans and
Land Mark Decision (never decided before) Limiting a States right to Tax (New Sea Escape Cruise, Ltd v. Department of Revenue, 823 So.2d 161 (Fla 4th DCA 2002), approved, 894 So.2d 954 (Fla 2005) reported in BNA DAILY TAX REPORT July 1, 2002).
Mr. Marini is admitted
to practice before the U.S. Tax Court.
He is also a member of the Florida Bar, member of A.I.T.C.
(Association of International Tax Consultants), and the Florida
International Tax Group, which is an invitational only group, of the
best International Tax Advisors in the State of Florida.
Mr. Marini is able to transact business in English and Italian.
to forming Marini & Associates, P.A.
Mr. Marini was with Arthur
Andersen & Co. (AA), in Miami, Florida and was listed as a
firm-wide International Tax Specialist in AA’s Worldwide
Directory. Mr. Marini was 1
of 15 tax professionals, with whom AA recommended consulting with when
advising clients on international tax issues. In addition AA considered
Mr. Marini as an International Shipping Specialist.
Bachelor of Science in Accounting, Villanova University, Villanova,
Pennsylvania, 1979 Magna Cum Laude; Juris Doctor, Villanova University,
School of Law, Villanova, Pennsylvania, 1982; and LLM (Taxation),
University of Miami School of Law, Coral Gables, Florida, 1985.
S. Blumenfeld, Of
Mr. Blumenfeld concentrates his practice in the areas of International Tax and Estate Planning, Probate Law, and Representation of Resident and Non-Resident Aliens before the IRS.
Prior to joining Marini & Associates, P.A., he spent 32 years as the Senior Attorney with the Internal Revenue Service (IRS), Office of Deputy Commissioner, International. While with the IRS, he examined approximately 2,000 Estate Tax Returns and litigated various international and tax issues associated with these returns.
As a result of his experience, he has extensive knowledge of the issues associated with and the preparation of U.S. Estate Tax Returns for Resident and Non-Resident Aliens, Gift Tax Returns, Form 706QDT and Qualified Domestic Trusts.
Mr. Blumenfeld is admitted to practice before the U.S. Tax Court. He is also a member of the Ohio Bar and he is a member of the Florida International Tax Group, which is an invitational only group, of the best International Tax Advisors in the State of Florida.
Frank Kalbacher, IRS Enrolled Agent
Mr. Kalbacher concentrates his practice in the areas of Representation before the Collection Division of the Internal Revenue Service (IRS). Including representation concerning:
Offers in Compromise
Installment Payment Plans
Penalty Abatement and
Unpaid Payroll Taxes & Responsible Party Defenses.
Prior to working with Marini & Associates, P.A., Frank spent 25 years as a Revenue Officer and Collections Program Analyst with the IRS.
While with the IRS he was responsible for:
Collection of Past Due Accounts and
Was an Offer in Compromise Specialist.
Frank has extensive knowledge of all aspects of IRS procedures as relates to collection activity, reports, programs and systems.
He has also written numerous technical materials for the IRS including:
Several Chapters of the Internal Revenue Manual (IRM)
Including the Offer in Compromise chapters of the Internal Revenue Manual (IRM).
His experience, both in the field and as an IRS headquarters analyst, provides him with the unique ability to address all aspects of collection procedures in his dealings with the government. He has enjoyed considerable success in representing his clients.
Bachelor of Science, University of Maryland, 1977, post graduate studies at Catholic University, Washington, D.C., 1978 –1979.