The taxpayer win in Home Concrete & Supply will have a huge trickle down effect too, not just impacting these cases. Robert McKenzie, tax lawyer with Chicago’s Arnstein & Lehr LLP said four clients of his firm with similar issues would likely reap tax savings approaching $40 million. Indeed, some reports say the case calls into question up to $1 billion in tax revenues.
1.10 While the process is not mandated by statute, the Service has, for over 60 years, provided taxpayers with an administrative alternative to litigating their tax disputes in court [Reg. § 601.106]. Now commonly referred to as Appeals, this administrative branch of the IRS generally has the final power and authority of the IRS to determine audit liabilities of taxpayers