Tuesday, July 12, 2016

What is the hardest case you won working as a lawyer?

Pretty definitely the case which led to the publication of Internal Revenue Service Technical Advice Memoranda 2004-53012 http://ift.tt/29UzIh2rs-wd/0453012.pdf and 2004-53013.   http://ift.tt/29UzIh2rs-wd/0....  Three solid years of work, complex issues, difficult facts, and opposed by an IRS task force that numbered about 50 members. 

Fortunately, there were several people in the IRS that were willing to listen to the facts, consider the issues fairly, and work hard to come up with the right ruling.  Frankly, it's less accurate to view this as a "win"; it's really the system working as it should, with dedicated practitioners on both sides of the issue.

But I will always remember the experience of laying out my case to a large room full of skeptical, deeply experienced IRS agents, and the moments when I could feel the beginning of a shift in attitude from the other side.

(If anyone is having trouble sleeping at night, I heartily recommend reading the above documents.  The obscurity of the issue, along with the numerous redactions, make it even more impenetrable than usual.)



Read other answers by Andrew Weill on Quora: Read more answers on Quora.

from Quora http://ift.tt/29Bsji1

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