I began my tax career as an undergraduate at Georgetown University in Washington D.C. in 1966, working for the National Office of the Internal Revenue Service on a work-study program. In 1967, I transferred to the IRS in Chicago, where I worked until midway through my senior year at the University of Chicago Law School. I then began working in private practice. I have practiced tax law in Chicago for more than 33 years. My office is on LaSalle Street, a few blocks from the IRS District, Appeals and Counsel Offices, as well as from the building where the United States Tax Court holds its sessions in Chicago. Although based in Chicago, I service clients anywhere in the State of Illinois and the northwest portion of Indiana. Due to the nature of IRS practice, I also have successfully served clients as far away as Florida, the East Coast and the West Coast. I have successfully handled IRS audits, appeals and trials in the United States Tax Court. One of my earliest Tax Court victories was a landmark decision, the first under the "timely mailing, timely filing statute." In this case, I convinced the Court that the Internal Revenue Service had mailed its Notice of Deficiency two days too late, thereby voiding an assessment of several hundred thousand dollars. I have successfully had clients determined to be "innocent spouses," thereby relieving them of large debts incurred on previously filed joint income tax returns. I also have had considerable success in having trust fund recovery penalties significantly reduced or abated in full. In one such case, the IRS abated a liability of more than $250,000 and released a previously filed lien. In other cases, implementation of my recommendation that the incorporated business be closed saved clients thousands of dollars in interest, deposit, late filing and late payment penalties.
I also have secured Offers in Compromise for my clients, compromising liabilities for far less than the amount owed. Where the client is not a candidate for an Offer, I have had wage levies released and monthly payment arrangements set up. In addition, I have been successful in having Federal tax liens released due to the expiration of the statute of limitations on collection, subordinated to mortgages of new lenders to allow refinancing and/or discharged to enable the sale of real estate to be completed, notwithstanding the fact that the IRS was not paid in full and the client still owed a large IRS balance. In a case where the IRS filed suit in the District Court to reduce their $1.2 million claim to judgment, I convinced the Service to settle for $50,000 due to the statute of limitations. In other cases where the IRS had been demanding payment of large alleged debts, I successfully obtained refunds from the IRS of more than $100,000. Just because the IRS says you owe them monies does NOT make it so.