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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.