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Argyropoulos v Birnbaum timeline
9 months ago
late 1999 DA retained Birbbaum as for self and tax preparer for Prima
2/23/2009 CBA: Birnbaum placed on 3 years probation with stayed revocation of license.
6/29/13 CBA: Birnbaum license suspended for 5 years and placed on probation ordered not to engage in activities of a CPA.
11/18/14 IRS: Birnbaum suspended from practicing before the IRS
10/11/99 Prima formed
8/24/11 I-Dea Holdings, Inc formed
1/20/12 I-Dea Holdings, Inc. 2011 T/R (Form 1120) prepared by Birnbaum
3/15/2012 S-Corp Election Form 2553 filing due date to be effective for TY 2012 Form 2553 requires signature of an Officer of the company.
8/9/12 Memo from Kime to DA and Gayl outlining tax issues created by S-election
9/7/12 Converted I-Dea Holdings, Inc. to LLC 1120/S for Inc.: Short year 1/1/12 - 9/7/12 1065 for LLC: Short year 9/8/12 - 12/31/12
2/25/13 1065 T/R for I-Dea Holdings LLC prepared by Birnbaum / Roman Wasylyn for 1/1/12/12/31/12 reporting ord. bus loss ($723,536) PLR request (9/24) states this return was a mistake LLC should be disregarded entity and if PLR granted, a short year T/R for Inc. period would be filed through 11/12/12 (not 9/7/12)
10/27/14 1120 T/R for I-Dea Holdings Inc prepared by Birnbaum / BK&Co for 1/1/12/12/31/12 reporting taxable income/loss ($723,536)
6/13/14 IRS letter to I-Dea Holdings , Inc. notifying 2012 TY selected for examination
5/21/15 IRS letter to DA notifying 2012, 2013 and 2014 TY selected for examination
7/2/15 IRS letter to Prima Inc. notifying 2012 TY selected for examination
7/20/16 3 separate letters from IRS concerning examination determinations to Prima Holdings, Inc. and Prima Holdings LLC and D. Argyropoulos
5/15/17 Letter from from DA and I-Dea Holdings. Inc. to IRS protesting IRS examination determination results citing PLR approved S-Corporation election
7/21/16 PLR Request submitted to IRS from I-Dea Holdings Inc blaming Birnbaum for failure to file S-Election
3/3/17 IRS Approved PLR allowing S-Election (PLR-127362-16)
3/4/15 Letter from IRS to I-Dea Holdings Inc. stating since no reply to request for information, IRS calculated tax and proposed penalties.
Late July 2015 PLR request (pg 10/24) states terminated Birnbaum after learning he did not file S-Election
8/9/12 Email from Kime to Levine explaining he "learned that the accountant had made an S Election for I-Dea Holdings. Ass a result our preferred stock does not work." .... "I think the cleaner and better approach is to convert I-Dea Holdings Inc. into an LLC and create a class of units that mirrors the preferred stock described in the PPM."
8/22/12 Email exchange between Gayl and Birnbaum wherein asks Birnbaum to contact Levine; Birnbaum says still in hospital and asks why; Gayl replies "He is doing the conversion of I-Dea Holdings from S-Corp to a LLC." PLR Request Ex. A-3
8/20-21/12 Email exchange asking Birnbaum to review lease between Prima and I-Dea and saying he is unresponsive to calls so sending request via email; Birbaum replies he's in the hospital. PLR Request Ex. A-3
8/23/12 Email exchange between Gayl and Birbaum wherein Birnbaum repiles "The conversion works and is a snap." PLR Request Ex. A-3
8/17-20/12 Email chain from Levine to DAstating "Holdco from S-Corp to LLC. Please chack with accountant and confirm." DA copied to Birnbaum asking Levine to ask Birnbaum any question; Levine replying "No questions. Just confirmation of his awareness." DA telling Birnbaum to plz reply; Birnbaum replying Let me know. Fell free to give me a call." PLR Ex. 2
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