Wilenchik & Bartness attorney Jack Wilenchik won a Motion to Dismiss a $100,000 tax deficiency in Utah federal district court, and attorney’s fees under IRC 7430. Mr. Wilenchik argued that under IRC 6502 the government has ten years to collect a tax after it has been assessed, and that period had expired. In response, the government incorrectly argued that the period had been extended by a settlement agreement between the Defendant and the government. The Court agreed with Wilenchik and Bartness and ordered the suit dismissed.
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