Daylan A. Nyarko, Esq.

Daylan A. Nyarko is a tax controversy attorney with extensive experience representing high-net-worth individuals and closely held businesses in both civil and criminal tax matters before the Internal Revenue Service and state taxing authorities. She has practiced law since 2009 and has maintained her own tax controversy practice since 2015.

Her practice focuses on federal tax controversies involving high-net-worth individuals and small business corporations with annual gross receipts of approximately $25 million or less, including IRS examinations, administrative appeals, and litigation before the United States Tax Court. She has also served as a consultant in matters involving complex income tax issues, reasonable compensation, flow-through entity matters, penalty defenses, and collection alternatives.

Areas of Focus

• Representation of closely held corporations and S corporations (under $25M in gross receipts)
• IRS examinations and audits (field, office, and correspondence)
• IRS Appeals and administrative resolution of tax controversies
• U.S. Tax Court litigation and settlement
• Flow-through entity taxation (S corporations, partnerships, LLCs)
• Reasonable compensation and owner employee issues
• Civil penalties (accuracy related, late filing, late payment, FBAR/foreign reporting)
• Collection matters: offers in compromise, installment agreements, currently not collectible status, liens and levies
• Business expense substantiation, hobby loss and passive activity loss disputes
• Small business corporate structuring and tax elections

Representative Experience

• Represents a managing member of a Partnership involving complex business organization litigation including allegations of financial misconduct, payroll fraud, and violations of federal and state tax laws
• Represents Taxpayers facing simultaneous high-stakes civil and criminal exposure involving alleged multimillion-dollar Medicare billing matter
• Prepares and analyzes financial records for use in multi-million-dollar civil litigation involving a closely held oil and gas business
• Represents Taxpayers before the IRS in multi-million-dollar federal income-tax disputes involving six-figure penalties
• Represents Taxpayers before the IRS in complex Bank Secrecy Act audits involving alleged anti-money-laundering violations
• Represented Taxpayer before the U.S. Tax Court where assessed seven-figure, multi-year tax debt arose subsequent to high-net-worth divorce
• Represents high-net-worth Taxpayers before the New York State Department of Taxation and Finance in complex income-tax audits
• Represented Taxpayer before the U.S. Department of Justice Tax Division in a federal matter alleging conspiracy to commit wire fraud
• Provides forensic accounting analyses in civil litigation matters involving closely held businesses

Licenses & Admissions

• Licensed Attorney, Illinois Bar, admitted December 2009
• Admitted to Practice, United States Tax Court, March 2018
• Admitted to Practice before the IRS under IRS Circular 230
• American Bar Association Taxation Division Membership