In this article, IRS attorney Robert E. McKenzie discusses the IRS audit system.
From the Government’s perspective, statutes of limitation restrict the taxpayer’s right to claim a refund of
overpaid tax or initiate litigation to obtain a refund. From the taxpayer’s perspective, statutes of limitation
prevent the IRS from collecting a deficiency in tax or beginning a civil or criminal case. In short, statutes of
limitation provide a date of finality after which actions taken by the IRS or the taxpayer cannot be disturbed by
the other party
And Chicago tax lawyer Robert E. McKenzie, who has defended rich folks claiming losses on everything from deer farms to race horses to yachts, says the Romneys -–despite the fact that Ann Romney’s statements on what dressage has done for her personally suggests lack of profit motive– likely did all the paperwork right and can assert they thought they’d make a profit, even if they never do. “The way I would argue it is `this horse competed in the Olympics and we’ll breed it and make money off the foal’,’’ says McKenzie. “When you’re that rich you can afford to have talented tax advisers.”