Congress has recently passed legislation, which creates the Tax Whistleblower Reward Program. Informants are now entitled to a guaranteed minimum reward of 15% and a maximum of 30% of any tax that is collected by the IRS as a derivative result of information provided by an informant. If you have information on at least $2,000,000 in unpaid tax, contact the former IRS attorneys of www.rewardtax.com. We practice exclusively in tax advice and controversy. With over thirty years of first hand combined experience serving as former legal counsel for the IRS and the US Tax Court we win the cases others lose! Call or email us today... and enter the gateway to your legal success! Stientjes & Tolu, LLC is a law firm practicing exclusively in the areas of tax advice and controversy. Our lawyers have over thirty years of first hand combined experience acquired while serving as former legal counsel for the Internal Revenue Service and the United States Tax Court. Three of our attorneys hold Masters of Law Degree in Taxation from the most prestigious law schools in the country. In addition, many of our attorneys formerly practiced law in the largest national law firms. With this government and "big firm" experience our attorneys strive to deliver the highest quality legal services at a more economical cost. Our firm serves individuals and businesses located throughout the United States and abroad. Because of our size and unique expertise we provide direct and personal contact to each and every client. We employ only "the best of the best" to insure that every client receives the highest level of service. Unlike many large firms, our partners will participate in every aspect and at all levels of your representation. At Stientjes & Tolu, LLC every client receives accessibility, responsiveness, and personal commitment from each and every member of our team. We represent clients before the Internal Revenue Service, the United States Tax Court, Federal Court of Claims, Federal District Courts, as well as in private tax planning matters. Welcome to Stientjes & Tolu, LLC - your gateway to success! Robert Stientjes, Principal Rob represents individuals and business clients exclusively in the areas of Tax Advice, Controversy and Employee Benefits. Rob has litigated and negotiated settlements for clients involved in "Listed Transactions" deemed by the IRS to be abusive tax-shelter arrangements. Rob represents clients before the Internal Revenue Service's Examination Division, Appeals Division, the United States Tax Court, the Court of Federal Claims, and various United States District Courts. Rob counsels clients before the IRS with respect to non-cash charitable contributions, deferred compensation, offshore trusts and corporations, discharge of indebtedness income, and Federal excise tax. In addition, Rob has significant experience with the Tax-Exempt and Government Entities (TE/GE) division of the IRS before whom he has represented numerous individuals and business and against whom he has litigated multiple issues significant to the employee benefits field. Rob's tax advice practice includes advising clients with respect to I.R.C. section 412(i) retirement plans, termination of defined benefit pension plans, and medical expense reimbursement plans. He also counsels clients with respect to the appropriate tax structure of charitable contributions and formation of tax-exempt corporations. Prior to entering private practice, Rob was the Attorney-Advisor to the Chief Judge of the U.S. Tax Court and Senior Attorney in the Office of Chief Counsel to the IRS. PRACTICE AREAS Federal Employee Benefits Federal Income Tax Employment Tax Excise Tax EDUCATION The Georgetown School of Law, LL.M in Taxation with distinction, 2001 University of Missouri, J.D., Certificate in Tax, 1999 University of Missouri, B.A., 1995 BAR ADIMSSIONS Missouri United States District Courts in Missouri United States Tax Court United States Court of Federal Claims SPEECHES/LECTURES - Speaker, Federal Taxation Seminar, University of Missouri School of Law, May 2005 - Speaker, Settlement Strategies for Federal Tax Controversies, Bar Association of Missouri-St. Louis, April 2003 Evita Tolu, Counsel Evita is a counsel in the general business and tax groups in the St. Louis Office of Stientjes & Tolu LLC. She advises her clients on corporate structuring and reorganizations, successor liability issues, pass through entity planning, business entity selection and formation, tax treatment of various business entities and tax driven transactions. Evita has significant experience in documenting asset and stock sale transaction for closely held companies as well as like-kind exchange transactions. Evita also assists her business clients with tax collection matters and has significant experience in settling high dollar tax liabilities through controlled collection such as the offer-in-compromise process or installment arrangements with the Internal Revenue Service. She advises clients on the IRS lien and levy matters, release, discharge and subordination of tax liens, as well as, alter ego, nominee, transferee and fraudulent conveyance matters. PRACTICE EMPHASIS General business Tax planning and collection EDUCATION St. Louis University School of Law, J.D., magna cum laude, 2000, top 2%, Order of the Coif University of Tula, Russia, B.A./M.A., summa cum laude, 1990, top 1% with High Honors NOTE In 2005, Evita was named as one of the "40 Most Influential Business People Under 40" in the St. Louis Metropolitan area by the St. Louis Business Journal. BAR ADMISSIONS California Illinois Missouri United States Tax Court United States District Court for the Eastern District of Missouri United States District Court for the Central, Southern, and Northern Districts of Illinois Shine Lin, Associate Shine is an associate in the St. Louis office of Stientjes & Tolu LLC in the tax division. Shine concentrates his practice on representing individual and business clients in tax controversies against the Internal Revenue Service. Shine is familiar with the IRS administrative procedures and provides client representation at all levels of the IRS review. Shine counsels clients in all aspects of the examination process, appeals, collection, litigation and alternative dispute resolution. Shine also represents clients before state taxing authorities. Prior to joining our firm, Shine was a clerk for the Florida Attorney General's Office in the Economic Crimes Division where he assisted the Attorney General in pursuing individuals and businesses in violation of laws governing economic relations. PRACTICE EMPHASIS Federal Income Tax Employment Tax Excise Tax EDUCATION Washington University School of Law, LL.M. in Taxation, 2005 Florida State University College of Law, J.D., 2004 University of California in Berkeley B.A., 1999 BAR ADMISSIONS Missouri United States Tax Court United States Court of Federal Claims PROFESSIONAL AFFILIATIONS & ACTIVITIES American Bar Association The Missouri Bar The Bar Association of Metropolitan St. Louis TAX CONTROVERSY Tax Litigation involving - Federal income tax - Employment tax - Excise tax - Tax shelter and promoter liability (6700 penalty) defense - Examination/Appeals/Litigation Tax Collection Matters - Tax advice in bankruptcy proceedings and reorganizations - Controlled Collection (Offer in Compromise/Installment Agreements) - Lien and Levy Matters - Release/discharge/subordination of Tax Lien - Determination of Priority of Tax Lien - Alter Ego/Nominee/Transferee/Fraudulent Conveyance Issues Criminal Tax Matters - Tax related white collar criminal defense - Tax shelter and promoter liability defense Miscellaneous Tax Matters - Validity of the Internal Revenue statutes and regulations under the U.S. Constitution - IRS abuse of discretion - Penalty abatements TAX MALPRACTICE - Breach of Contract by Representative - Negligence/Failure to Use Due Care (with respect to tax planning/representation/litigation) - Failure to properly Inform - Imposition of Penalty due to Errors of Attorney/Accountant TAX PLANNING - Business Planning - Corporate structuring/restructurings & reorganizations - Pass-through entity planning - Limited liability companies (LLC) - Limited liability partnerships (LLP) - Limited and general partnerships - Joint ventures - S corporations - Family limited partnerships - Individual Planning - Pension and profit-sharing plan distributions - Variable annuities, life insurance and investments - Asset protection - Asset and stock sale transactions - Employee benefits planning - Real estate - Distressed real estate - 1031 like-kind exchanges - Installment sales - Deferred like-kind exchanges - Charitable giving - Charitable remainder (CRATs and CRUTs) trusts - Lead trusts - Private foundations Publications 1. IRS appeal procedure 2. IRS audit examination procedure RECENTLY OUR ATTORNEYS SUCCESSFULLY REPRESENTED: - One of the United States' largest manufacturing companies, convincing the IRS national office to concede a significant employment tax issue. - An international conglomerate regarding its transfer pricing of worldwide sales of proprietary products. - One of the United States' largest energy producing companies concerning the excise taxation of export products. - An international corporation in the transportation industry regarding income and excise tax issues. - A telecommunications company in the taxation of intangible assets. - A domestic service company regarding the interpretation of the consolidated return regulations. - A high profile individual concerning the validity of a particular treasury regulation. - Various corporate executives in white-collar criminal investigations. - Various corporations and individuals in the IRS tax shelter investigations. - An international company on the valuation of worldwide assets for foreign tax credit purposes. - A privately held company in the dispute with the IRS where the IRS was convinced that charitable gifts of particular intangible property do not fall under the ordinary income property rules for charitable giving, do not violate the partial interest rules, and are equal in value to amounts claimed on relevant income tax returns. - A domestic company in a dispute related to the constitutionality of excise tax issues in the stream of interstate commerce. - A closely held company in lien and levy matters. - A closely held company in the United States Tax Court proceedings in the substantiation of business expenses issues. - Several business clients involved in the certain deferred compensation arrangements where the IRS agreed to respect these transactions. Please read our legal disclaimers before contacting us via email. Then simply fill out the form below. You are also welcome to contact us via phone or fax at: Direct: 314-872-3988 Facsimile: 314-872-7374 Tom Tolu represents individuals and business clients in all phases of federal tax controversy, including proceedings before the Internal Revenue Service's examination division, appeals office, and the office of Chief Counsel. Tom has litigated and assisted with numerous cases in the United States Tax Court, United States District Courts, Bankruptcy Courts, and the United States Court of Federal Claims. Tom's litigation experience includes proper interpretation and application of tax law with respect to family limited partnerships, closely held companies, asset valuation, foreign tax credits, tax shelter and promoter liability matters, employment tax, excise tax, penalty abatement, IRS abuse of discretion, and the validity of internal revenue statutes and regulations under the United States Constitution. Tom also has extensive experience on a broad range of federal summons issues. Tom is widely regarded as the foremost expert in tax collection matters and estate and gift tax litigation. Tom is also a professor at the St. Louis University School of Business, Department of Accounting where he teaches courses in Tax Administrative Procedure and Tax Litigation Procedure. PRACTICE EMPHASIS Federal Income Tax Estate & Gift Tax Planning Employment & Excise Tax White Collar Criminal Defense Appeals & Tax Collection EDUCATION Saint Louis University, J.D., 1983 George Mason University, B.S., 1978 NOTE Before entering the private practice of law, Tom served for 16 years with the Office of Chief Counsel of the Internal Revenue Service where he litigated cases for the Small Business/Self-Employed (SBSE) Division. Over the years, Tom assisted the Chief Counsel's office with examination and criminal investigations, as well as, advising the examination and criminal units of the IRS in developing issues, leading settlement negotiations, and litigating tax cases involving high dollar tax liabilities. Tom also served as a Special Assistant United States Attorney (SAUSA) while representing the IRS in bankruptcy proceedings involving complicated tax matters. BAR ADMISSIONS Missouri United States District Court, Eastern District of Missouri United States Tax Court SPEECHES/LECTURES Tom has taught numerous classes to IRS personnel on tax issues in bankruptcy, collection and appeals. Over the years, Tom taught IRS attorneys from the Office of Chief Counsel on a nation wide basis on all aspects of collection matters including liens, levies, summons, trust funds, property tax, release, and discharge of tax liability, offers-in-compromise, and installment arrangements. Stientjes taw law, taxlaw, lawyer st. louis , IRS attorney, IRS lawyer, criminal tax, tax shelter defense, pension plan, benefits attorney, ERISA attorney, ERISA lawyer, tax planning lawyer, tax planning attorney, Tax transaction, Evita Tolu, Discharge of lien, Release of tax lien, Notice of federal tax lien, NFTL, Installment agreement, Offer in compromise, Internal Revenue Code, FBAR, F-BAR, Tax penalty, IRC, Treasury Regulations, Tax Malpractice, Accountant Malpractice, Legal tax malpractice, Tax Malpractice Litigation, Transferee liability, Alter-ego liability, Bank Levy, Tax resolution, Sham trusts, Domestic trust, Foreign Trust, Priority of tax, Tax priority, Tax Deductions, Tax Credit, Tax Procedure, Judicial Review, TEFRA, RAR, Revenue Agent's Report, SND, Notice of Deficiency, Statutory Notice of Deficiency, Enforcement of Summons, Criminal Tax, Criminal Investigation Division, SBSE, SB/SE, LMSB, Failure to file, Tax adjustments, Tax disputes, Bankruptcy tax , Alternative minimum tax, Trust funds, Trust fund taxes, Family limited partnerships, IRS attorney, Former IRS attorney, Tax litigator, Tax litigation, 6672 penalty, Refund action, Tax Class action, 6700, Promoter penalties , Tax shelter promoter, Subrogation, Tax Bond, Son of Boss, SOB, OEL, Offshore employee leasing, Tax abuse, ATAT, Abusive tax avoidance transaction, Listed transaction, CDP, Collection due process, Doubt as to collectibility, Doubt as to liability, ETA, Effective tax administration, Short term deferred offer, Economic hardship, National standard, Tax protestor, Tax resistor, IRS Audits , IRS Collection , Offers in Compromise , Estate planning , State tax problems , Seizure of wages and bank accounts , Employment tax problems , Wealth protection, Asset protection, Wealth preservation, Anti-Tax Law Schemes , Abusive Home-Based Business Schemes , Abusive Trust Schemes , Misuse of the Disabled Access Credit , Abusive Offshore Schemes , Employee Plans Abusive Tax Transactions , Exempt Organization Abusive Tax Avoidance Transactions , Section 861 arguments, Abuse of the Disabled Access Credit, foreign-source income , Form 843 Tax Abatement, Return Preparer Fraud, Abuse of Charitable Organizations and Deductions, Employment Tax Evasion, No Gain Deduction, Pyramiding, Unreliable Third Party Payers, Misclassifying worker status, Paying Employees in Cash, OCCP , Offshore Credit Card Program, Taxpayer advocate, TA, FOI, Freedom of Information, Robert Rob Tolu, Rob Tolu, criminal tax attorney, criminal tax defense, criminal tax lawyer. Looking for a criminal tax attorney? You've come to the right place! We offer criminal tax defense by some of the best criminal tax lawyers in the country. If you're needing a criminal tax attorney then visit our site to find out about our criminal tax defense and criminal tax lawyers. Estate Planning estate planning: an overview An estate is the total property, real and personal, owned by an individual prior to distribution through a trust or will. Real property is real estate and personal property includes everything else, for example cars, household items, and bank accounts. Estate planning distributes the real and personal property to an individual's heirs. Estate planning is the process by which an individual or family arranges the transfer of assets in anticipation of death. An estate plan aims to preserve the maximum amount of wealth possible for the intended beneficiaries and flexibility for the individual prior to death. A major concern for drafters of estate plans is federal and state tax law. Wills and trusts are common ways in which individuals dispose of their wealth. (See Estates and Trusts). Trusts, unlike wills, have the benefit of avoiding probate, a lengthy and costly legal process that oversees the transfer of assets. Sometimes, though, it will be useful to make inter vivos gifts (gifts made while the donor is alive) in order to minimize taxes. The Federal Gift Tax exempts certain levels of lifetime gifts. (See Estate Tax) An Estate is the entirety of a property, real and personal, owned by an individual prior to distribution through a trust or will. Estate planning is the process by which an individual, or nuclear family with the person's consent and approval, arranges the transfer of assets to heirs or other beneficiaries. The reason for this is to provide the family, or anonymous miscellaneous beneficiaries, with legal rights to the property after the individual has passed away. Aspects of Estate Planning, include: * Trusts * Wills * Uniform Probate Code * Gift Tax * Dynasty Trust * Joint Tenency A good Estate Planning lawyer can do more than just manufacture a simple will. Estate planning also typically minimizes potential taxes and fees, and sets up contingency planning to make sure that your wishes regarding which items are allocated and who the main beneficiaries are. Many trusts are created as an alternative to or in conjunction with a will and other elements of estate planning. State law establishes the framework for determining the validity and limits for both. An Estate Planner can assist you with organizing your personal and business records such as: * Brokerage Accounts * Retirement Plans * Savings and Checking Accounts * Insurance Policies * Business and Partnership Interests * Debt Personal Property An Estate Planner can also assist all other possible estate planning law concerns. If you are in need of an estate planning lawyer with solid experience in wills & estate planning let Stientjes & Tolu LLC. help you with your legal concerns. Estate planning can be stressful, let Stientjes & Tolu LLC take the stress out of estate planning. At Stientjes & Tolu estate planning is part of what we do. We specialize in estate planning... contact us to find out more. June 2007 Trust and Estate Attorney Robert Stientjes Trusts and Estates Attorney Robert Stientjes Trust law Estate law Wills Durable Power of Attorney Pre-nuptial agreements Marriage contract Pour over will Estate tax litigation Estate tax dispute Experience in estate planning Medical directive Medical power of attorney Business power of attorney Business succession attorney Trusts & Estates Attorney Tom Tolu Trust & Estate Attorney Thomas Tolu Charitable Remainder Annuity Trust (CRAT) Charitable Remainder Unity Trust (CRUT) Charitable Remainder Trust Charitable Lead Trust (CLT) Grantor CLT Lifetime Qualified Non-grantor CLT Non-qualifying Non grantor CLT Testamentary CLT Private Foundations Grant making foundations Private operating foundation exempt operating foundation exempt non for profit foundation exempt not for profit company foundation Defense attorney for Circular 230 violation Defense lawyer for Circular 230 violation Defense attorney professional responsibility practice before the IRS Complicated tax return preparation 1120 Complicated tax return preparation 1065 Tax return preparation 1040 Pay roll administration Pay roll taxe preparation Pay roll responsibilities Pay roll taxes Simple will Pour over will Complex will (married couple taking advantage of life time credit) Irrevocable Trust Asset Protection Non-Grantor Irrevocable Trust Domestic Grantor Trust Revocable Trust Complex Revocable Trust (married couple taking advantage of life time credit) Irrevocable Trust GRAT planning drafting Qualified Grantor Retained Interest Trust draft drafting GRIT drafting preparation Qualified GRUT planning preparation Qualified Grantor Retained Annuity Trust Qualified Personal Residence Trust QPRTs Charitable deduction planning Charitable Remainder Trusts Direct Charitable Annuities Life Insurance Trusts Irrevocable Life Insurance Trust Transfers between spouses Non tax planning Tax planning Tax deferral Generation skipping tax Private annuity Spousal remainder trust Trust administration advice Trustee services Personal representative services Beneficiary owned trust Income from gifts and bequest tax Federal transfer taxes Transfers between husband and wife Intentionally Defective Trust IDT Generation Skipping Trust Deduction for closely held business interests QFOBI Unified Transfer Tax Credit Power of appointment trust General power of attorney tax Indirect constructive reciprocal transfer Resulting trust Constructive trust Gift tax procedure Section 2036 Internal Revenue Code Section 2037 Internal Revenue Code Family limited partnership Limited liability company Limited liability partnership Corporate tax taxation Tax planning closely held business Tax planning closely held company Generation skipping tax valuation rules Liquidation under 2704 Exemptions deductions and credits Direct skip transfer tax Inter vivos transfers Special needs trust Buy sell agreements Non trust split interest transfers Direct Charitable Annuities Estate trust Loss of exclusion Deferral of Tax payment Transfer of Wealth Inheritance Tax Accessions Tax Commercial Excise tax Property or Wealth tax Farmers Farmer Tax Closely held business company The kiddie tax Accumulation trust Elective gift splitting Beneficiary's Deed Transfer on Death IRA 401-K planning SEP plan