"Darrell Issa, This Generation's Joe McCarthy" In my most recent blog, I discuss the comments made by Lois Lerner, head of the IRS Tax-Exempt and Government Entities Division. Ms. Lerner commented on the IRS and tax exemption status of social…
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.
8-24-12 Robert E. McKenzie Appearance on Money For Lunch Talk Radio
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.”
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.”
How Foreign Investors Can Get A Green Card In Exchange For $1 Million