David Dickieson Prevails Before the IRS on Statute-of-Limitations Bar to Tax Assessment – Schertler Onorato Mead & Sears Schertler Onorato Mead & Sears

Read Schertler Onorato Mead & Sears’ latest news.

David Dickieson Prevails Before the IRS on Statute-of-Limitations Bar to Tax Assessment


OCTOBER 2016

Schertler & Onorato partner David Dickieson, who formerly served as a senior trial attorney in the Department of Justice Tax Division, obtained a complete reversal of an IRS plan to assess the owners of a popular Denver, Colorado restaurant with taxes, interest, and penalties in excess of $200,000.   The IRS intended to rely on an extended statute of limitations tied to an alleged delay in a foreign bank’s response to an IRS subpoena.  Mr. Dickieson successfully showed that the statute of limitations could not have been extended for the years involved in the audit and that the IRS therefore was legally blocked from making any assessment.  The IRS issued an examination report with a cover letter conceding that the taxpayers “have no legal obligation to pay the amount shown” on the report.

Recent News
  • NOVEMBER 2020
  • David Schertler Obtains Probationary Sentence in National Science Foundation Fraud Prosecution
  • NOVEMBER 2020
  • Schertler Onorato Mead & Sears Receives National and Metropolitan Tier rankings for its White-Collar Criminal Defense Practice in “Best Law Firms” 2021 Edition
  • AUGUST 2020
  • David Schertler Named Best Lawyers© “Lawyer of the Year” for Criminal Defense in the Washington, D.C. Area
  • AUGUST 2020
  • David Schertler, Danny Onorato, Chris Mead, and Stuart Sears Named to 2021 Best Lawyers© List
  • APRIL 2020
  • David Schertler, Danny Onorato, and SOM&S Receive Chambers USA 2020 Rankings for White-Collar Crime and Government Investigations Practice
  • APRIL 2020
  • Four SOM&S Partners Are Named 2020 Super Lawyers; David Schertler and Danny Onorato Also Earn “Top 100” Super Lawyers Honors

EXPERIENCE. JUDGMENT. RESULTS.

To learn more about Schertler Onorato Mead & Sears