Offers in Compromise are an essential tool of tax enforcement because the IRS realizes that it is often better to get half a loaf of bread than none at all. However, for the fiscal year 2017, even though millions of taxpayers owed billions in unpaid taxes, the IRS received only 62,000 Offers in Compromise and it accepted approximately 25,000 of those, or a little less than half. This panel identifies when an Offer in Compromise should be considered and what makes a good offer so that you can increase the likelihood of having your next offer accepted.
Identify procedures and best practices when filing different kinds of Offers in Compromise (OICs).
Robert E. McKenzie is a partner of Saul Ewing Arnstein & Lehr LLP of Chicago, Illinois, concentrating his practice in representation before the Internal Revenue Service and state agencies. He has lectured extensively on the subject of taxation. He has presented courses before thousands of CPA’s, attorneys, and enrolled agents nationwide. He has made numerous media appearances, including Dateline NBC and The ABC Nightly News. He dedicates a significant portion of his time to representation before the IRS. In 2017 Mr. McKenzie received the American Bar Association Civil and Criminal Tax Penalties Committee’s Jules Ritholz Award. The award recognizes McKenzie’s dedication and achievement in the field of tax controversy. From 2009 to 2011, Mr. McKenzie was a member of the IRS Advisory Council, which advises IRS management. He has been selected as a Fellow of the American College of Tax Counsel and served as its President from 2017 to 2018. He was vice-chair of the ABA Tax Section (2003-2005). Mr. McKenzie is past chairman of the Employment Tax Committee, past co-chair of the Task Force for Bankruptcy Legislation of the ABA Section on Taxation, and past chairman of the Chicago Bar Association Federal Tax Committee. He was Dean of the National Tax Practice Institute (1998-2002). Additional information can be found on Mr. McKenzie’s website, mckenzielaw.com, where he also keeps an active tax blog.
Mr. McKenzie received his J.D. with High Honors from the Illinois Institute of Technology, Chicago Kent College of Law.
Daniel Rosefelt has over 20 years of experience in solving complex civil and criminal tax problems for his clients. He regularly appears before the Internal Revenue Service, the Comptroller of Maryland, District of Columbia Office of Tax & Revenue, and other state tax agencies for a variety of serious tax matters.
Fran Obeid is the founder of MFO Law. She represents individual and corporate clients in civil and criminal matters involving the Internal Revenue Service, state and city tax agencies, the tax division of the Department of Justice, the United States Attorney’s Office, the District Attorney’s Office, the New York State Attorney General as well as other government agencies.
Sarah A. Fields is an Enrolled Agent, working in the National Tax Controversy Dept of Prager MetisCPAs, led by Partner-In-Charge E. Martin Davidoff, CPA, Esq., and Partner Robbin Caruso, CPA,CGMA. Sarah has been a key member of the Davidoff/Caruso team for over 11 years and specializes in collection matters with the IRS and state tax agencies. She also has extensive experience in dealing with the State of NJ for tax examinations, primarily focused on audits of restaurants and family businesses.
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