Over the years the IRS offer in compromise program has been the subject of a great deal of criticism by Congress, the National Taxpayer Advocate and taxpayer representatives. The new initiative represents the most dramatic liberalization of IRS settlement policies ever announced. It represents a welcome change from an agency which has always placed substantial roadblocks to those seeking to compromise their tax obligations.
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.
“It’s a great result for my client,” said Robert McKenzie, a partner with Arnstein & Lehr, who represented a taxpayer in the Seventh Circuit Court of Appeals who lost to the government in a separate case.
“I’ve represented clients who paid large sums of money to each of those companies and were disgruntled with the services they received,” said Robert McKenzie, a partner in the Chicago-based law firm Arnstein & Lehr.
For example, one Chicago-based hot-dog-stand owner said his cost of goods sold was 50% of gross receipts, said Robert McKenzie, a partner in the law firm Arnstein & Lehr. “I know Chicago hot dogs are great, but he had a high cost.”
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“There are still lots of tax resolution services out there, but the three that filed for bankruptcy—TaxMasters, Roni Deutch and JK Harris—were the ones that engaged in heavy duty advertising on a national scale,” said Bob McKenzie, a tax partner at Arnstein & Lehr.
On March 7, 2012 the Internal Revenue Service announced a major expansion of its “Fresh Start” initiative to help struggling taxpayers by taking steps to provide new penalty relief to the unemployed and making Installment Agreements available to more people.
Despite your best efforts at diligently filing proper tax returns, the IRS can audit your tax returns and Robert McKenzie is a tax attorney who can help sort out the mess. Sometimes the audit results areworse than expected and other times with proper representation the process can be least intrusive. Inthis episode of Law Talk Radio we examine tax law from several perspectives
2-10-12 Robert E. McKenzie Quoted in Forbes Regarding Correspondence Audits