Reducing IRS Penalties

Procedural Requirements for Imposition of Penalties and Additions to Tax
The Internal Revenue Service Restructuring Act required that each notice imposing a penalty include the name of the penalty, the Code section imposing the penalty, and a computation of the penalty. The Act also requires the specific approval of IRS management to assess all non computer generated penalties unless excepted. This provision does not apply to failure to file penalties, failure to pay penalties, or to penalties for failure to pay estimated tax.

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Forbes Quote Regarding Romney's Tax Return & Hobby Losses: 7-19-12

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.”

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5-27-12 Forbes Blog: New IRS Offer In Compromise Policies

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.

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Robert E McKenzie Quoted in Two Forbes Articles on a Supreme Court Tax Case 4-26-12

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.

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