Notable Cases

Representative cases in private practice include Tax Court litigation involving over $50 million in foreign income at issue; a controversy involving millions in asserted tax liabilities related to reasonable compensation issue for corporate owners/officers and research and development credits; a controversy involving $8 million in taxes due by taxpayer in the New York real estate industry; recoupment of over $10 million in wrongful levy action involving brokerage account; achieved innocent spouse status for spouse of investor involving >$1 million in tax related to a conservation facade easement investment; abatement of penalties involving tax filing issue involving best-selling author; favorable resolution of renowned patent and inventor's tax liabilities; favorable resolution of $2 million of tax liabilities and abatement of penalties for nationally known supplier of building and architectural products; complete abatement of responsible person assessments in cases against officers in the offending corporations, in the amounts of $2 million and $300,000 respectively.

Ms. Kazenoff also has experience in cryptocurrency tax reporting and tax audits including achieving IRS agreement to full allowance of an $800k charitable donation of Bitcoin for high profile tech industry author. She has given presentations on the taxation of cryptocurrency and current IRS initiatives to ensure cryptocurrency compliance.

Ms. Kazenoff has reached favorable settlements involving Sales Tax assessments of over $6 million for a large corporation, saving over $4 million for the client; favorable settlement agreements for both corporate and individual officers liable for withholding taxes in separate cases where over $1.7 million and $2 million was owed, respectively, and sales taxes owed of over $1.5 million; favorable settlements involving New York State residency issues resulting in "no change" residency audits; resolution of cases for numerous clients involving both Offers and Installment Payment Agreements with both the IRS and New York State Collection Divisions. She has resolved cases in pending court cases, saving thousands in litigation costs for clients. She has successfully represented clients in the abatements of penalties in various situations involving hundreds of thousands of dollars, including late filing, late payment and negligence penalty cases due to reasonable cause, reached favorable settlements in collection cases with both the IRS and New York State involving high profile individuals and businesses, including a $17 million options case, and negotiated favorable settlements with both the IRS and Department of Labor involving pension plan qualification and compliance issues. She successfully challenged a $1.3 million adjustment against a non-profit corporation. She has successfully represented clients in the releases of levies and liens, negotiated installment payment agreements and offers in compromise, and in some cases collection activity was stayed altogether due to lack of collection potential. She has also negotiated favorable settlements and achieved "no change" results in a number of IRS and NYS examinations.


Internal Revenue Service Office of Chief Counsel experience and notable cases:

Ms. Kazenoff was a Senior Tax Attorney for the Internal Revenue Service's Office of Chief Counsel, Brooklyn District Counsel.  She litigated cases before the United States Tax Court and was counsel to the Brooklyn District's Employee Plans and Exempt Organizations Division. She was assigned to high profile cases involving the qualification of pension plans and excise tax issues. She was a member of Chief Counsel's Tax Exempt Bonds Initiative and was also a part of the Coordinated Examination Programs involving Colleges, Universities, and Hospitals involving major tax exempt institutions located in the North Atlantic Region.

Ms. Kazenoff was also counsel to the Collection Division responsible for the review of Offers in Compromise, priorities in Bankruptcy, and issues involving IRS Liens and Levies.  Ms. Kazenoff was an Instructor for Chief Counsel's Employee Plans Litigation Attorney Training Program in Washington, D.C. and also lectured to other Brooklyn District Counsel attorneys on Employee Benefit topics, including Prohibited Transactions and Minimum Funding Deficiencies. She was instrumental in changing the IRS Levy form to address unique issues involving assets held in qualified benefit plans.

Notable Cases at IRS:

Ms. Kazenoff was assigned to high profile cases while a Senior Attorney with IRS Chief Counsel:

• John J. Waters. v. Comm. (litigated Tax Court case involving computer leasing and application of at-risk limitations);

• Drexel, Burnham, Lambert Co.  Inc. et al., Debtor (handled pension issues involving reasonableness of actuarial assumptions in individual defined benefit plans in negotiation of United States' claims in bankruptcy);

• Wachtell, Lipton, Rosen & Katz v. Comm (litigated one of three test cases involving reasonableness of actuarial assumptions in individual defined benefit plans);

• Furniture Marketing Specialists Defined Benefit Pension Plan v. Comm. (Summary judgment in statute of limitations issue; negotiated sizeable settlement in IRS' favor):

• Cumberland Farms, Inc., Debtor (negotiated settlement of prohibited transaction and minimum funding deficiency excise tax claims re: pension plans);

• Morganbesser and International Union of Operating Engineers v. U.S. (key case involving exemption of pension plan as "labor organization" even though not qualified under ERISA),

• Doubleday & Company, Inc. v. U.S. (handled subsequent years issues including pension reversion issue and tax benefit rule involved in merger); 

• Estate of Eric Strober v. Comm. (computer leasing issue involved in estate case);

• Zuckerman v. Comm. (prevailed in proving embezzlement income involving second mortgage financing): 

• U.S. v. Massachusetts Institute of Technology (originated summons to MIT and referral for enforcement, IRS prevailed alleging waiver of attorney-client privilege in previously disclosed documents to Defense Contracting Audit Agency).