Photo of Cassandra S. Bradford

Cassandra S. Bradford

Associate

Education

Mercer University - B.A. International Affairs - May 2010. Honors Program

Georgia State University College of Law – J.D. - May 2015

Georgia State University J. Mack Robinson College of Business – M.B.A. – May 2015

Bar Admissions

Georgia

Court Admissions

Georgia Superior Court

Georgia Court of Appeals

Georgia Supreme Court

U.S. Tax Court

Profile

Sandy is an associate attorney in the Tax Controversy and Litigation Section in Atlanta.  She defends clients in tax audits, tax appeals, and litigation before the Tax Court.  Sandy’s practice spans a wide range of areas, including the following:

  • Overview of Practice Areas
    • Tax audits
    • Tax appeals 
    • Tax Court litigation
    • Tax refund claims
    • Penalty abatement requests
    • Private letter ruling requests
    • Tax collection defense
  • International Tax Matters 
    • Offshore Voluntary Disclosure Program (OVDP)
    • Streamline Domestic Offshore Procedure (SDOP)
    • Streamline Foreign Offshore Procedure (SFOP)
    • Delinquent International Information Return Submissions Procedure (DIIRSP)
    • Delinquent FBAR Submissions Procedure (DFSP)
    • Foreign account reporting (Form TD F 90-22.1, FinCEN Form 114, FBAR)
    • Foreign asset reporting (Form 8938)
    • Controlled foreign corporations (Form 5471)
    • Foreign-owned U.S. corporations (Form 5472)
    • Foreign corporations with U.S. business (Form 1120F)
    • Passive foreign investment company (Form 8621)
    • Foreign trusts (Form 3520 and Form 3520A)
    • Foreign transfers (Form 926)
    • Treaty-based tax return positions (Form 8833)
    • Expatriation tax issues (Form 8854)
    • Foreign earned income exclusion (Form 2555)
    • Foreign tax credits (Form 1116)
    • Transfer pricing
    • Check-the-box foreign entity classification elections (Form 8832)
  • Domestic Tax Matters
    • Conservation easement disputes 
    • Listed and Other Reportable transactions (Form 8886)
    • Material advisor issues (Form 8918)
    • Federal and state tax credit disputes
    • Captive insurance disputes
    • Employment tax issues
    • Estate tax issues
    • Worker-classification disputes (employee versus independent contractor)
    • Passive activity loss disputes 
    • Reasonable compensation disputes
    • Tax shelter promoter and fraudulent return preparer defense 
    • Trust fund penalty disputes 
    • Domestic Voluntary Disclosure Program representation
    • Excise tax issues
    • Lien withdrawal/discharge
    • Installment Agreements and Offers-in-Compromise

Tax Litigation

If a tax dispute cannot be resolved administratively with the IRS or state tax agency, litigation often ensues.  Sandy has handled several cases before the Tax Court.  A partial list of cases follows:

  • Friedman v. Commissioner, Tax Court Docket No. 24219-14
  • Geiger OSCP3, LLC v. Commissioner, Tax Court Docket No. 19587-17
  • Goddard v. Commissioner, Tax Court Docket No. 13513-17
  • Woods v. Commissioner, Tax Court Docket No. 12230-15
  • Woods v. Commissioner, Tax Court Docket No. 12231-15

IRS Administrative Rulings

  • IRS Private Letter Ruling _________ (ruling regarding a late portability election of the deceased spousal unused exclusion to decrease U.S. estate taxes)
  • IRS Private Letter Ruling 107272-17 (ruling regarding late Section 754 election and tiered-partnership structure)
  • IRS Private Letter Ruling 107273-17 (ruling regarding late Section 754 election and tiered-partnership structure)
  • IRS Private Letter Ruling 101616-17 (ruling regarding expatriation issues under Section 877A and the Offshore Voluntary Disclosure Program)

Prior Experience

Before working at Chamberlain, Sandy worked as a student attorney and graduate research assistant at the Philip C. Cook Low-Income Taxpayer Clinic for over two years.  During this time, Sandy represented numerous low-income clients in a wide range of tax disputes.  Sandy also had the opportunity to work with a national law firm on a Son-of-Boss shelter case while at the Clinic.

Professional Affiliations

  • Georgia Bar Tax Section
  • Atlanta Bar Tax Section