Bill Fritton: This was a gentleman who came to see us. This case was probably six years ago. He was an investment banker in the Washington D.C. area, a very bright guy, went to some of the top schools in the country. He had climbed the ladder in his investment banking firm and really had done a good job for himself, but he was saddled with this tax debt. He was in a business with some partners, and that business had gone south for whatever reason. I came in long after that fact. He was assessed a trust fund recovery penalty, which I spoke about earlier where if payroll taxes are not paid, they can come after you personally. He owed, at least the IRS thought that he owed, a couple hundred thousand dollars. He hired one of the bigger law firms in Washington to represent him and was with them for several years trying to resolve the problem. He had paid them upwards of over $50,000 in legal fees. In the end, they lost everything they tried to put forth in terms of the defense from my client and to get him out of the problem. An offering compromise was not a solution for him, because he made too much money. He had too many assets, and he was nervous that the IRS were going to start taking those assets to claim this $200,000.
So, he came into see us, and he had all his paperwork. He was meticulous with his paperwork, which really helped him out. He started telling me his story, and by the end of the story, I said you’re not liable for this tax, and he said, “what do you mean?” I said, “well for reasons A, B, and C, I don’t think you owe this tax.” He said, “Well, how can that be? I’ve had somebody representing me for two or three years. I’ve paid them all this money, why didn’t they say that?” He said, “how are you able to see that so quickly?” I said, “You know, because I’ve been doing it a long time, and you explained and I listened, and I delved into why this happened and why that happened. I said, but to be honest with you, you’ve already lost all of your appeals, it’s going to be very difficult for me to go back in and un-ring the bell.”
Long story short, I was able to find a way, a little known way, to go back and have the case reopened, and the IRS really struggled, as everybody did, with the case to understand the what’s and the why’s of why he didn’t owe. There was a lot of bookkeeping errors. There were a lot of things, nuances, that really had to not only be explained from our point of view, but had to be explained to the IRS so that they could buy in to the reason my client didn’t owe the money. At the end of the day, we got him off of everything. He walked away without paying the IRS a penny. He saved himself $200,000, and he was extremely happy for the result.