Arnstein & Lehr Tax Attorneys Secure IRS Concession for Client, Reversing Projected $61 Million Tax Bill

Business Wire, Dec 20, 2007

CHICAGO -- Robert E. McKenzie and Adam S. Fayne, attorneys with the Chicago law firm of Arnstein & Lehr LLP, who concentrate their practice in the area of tax controversy including representation before the Internal Revenue Service and state tax agencies, received for their client today, a United States citizen, a $61 million concession from the Internal Revenue Service. The IRS alleged that the client had a tax obligation to it in excess of $61 million due to a dispute over the client's residency.

The dispute centered around the client's residency status during certain tax years, where the client claimed residency in the Commonwealth of Northern Mariana Islands (CNMI), but the IRS failed to recognize the legitimacy of that residency. McKenzie and Fayne litigated the client's position through the United States Tax Court and under provisions for United States Competent Authority. After litigating, and working in conjunction with the CNMI government, the client's ultimate result was that no taxes were due to the United States, and the IRS conceded its Tax Court case in full, which led to a $61 million reduction that was originally alleged to be due from the client.