Memories of the Cold - Travel and the Work Mission
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| Cold as the ice blue air |
On December 22, 1990 I was working for Arthur Andersen. One of my corporate clients was contemplating a complex reorganization and we had requested a “ruling” on the tax consequences from the Internal Revenue Service (IRS). The IRS counsel had just informed us that they were likely to rule “adverse” but offered us an opportunity to meet with them the next day at IRS HQ in Washington D.C. to try and make our case.
I contacted my colleague in the Andersen National Office and we moved everything off our schedules to meet with IRS counsel. I scheduled my flight out from Denver’s old Stapleton International Airport. I ran home, packed for a one-day business meeting and headed to the airport in snow and record cold.
After we boarded the plane at around 5:30 pm, the pilot offered us two choices: Leave now and refuel in Kansas City. Wait in Denver for a fueling truck to fill up our plane and go nonstop to D.C. I don’t remember the methodology of the vote, but we opted to wait for a fueling truck in Denver.
And we waited. And we waited some more. Due to the extreme cold the fuel trucks were having issues and we were one plane in a long line. Then once fueling occurred we had to wait hours to be de-iced. It took so long that we watched two movies while sitting on the runway:
Pennies From Heaven and Presumed Innocent. We departed some time after 10:00 pm. With the time zone change it was right around 3:30 am when my head hit the pillow in my D.C. hotel room.
I met my D.C, colleague for breakfast at 7:30 and we discussed our strategy for the meeting. Essentially we had to convince the IRS that there was a primary business purpose for the transaction at hand, unrelated to its tax ramifications.
The IRS national office on Constitution Avenue is a rather foreboding and depressing looking place. From the outside it looks like a prison (IMO). On the inside, at least back then, it had the feel of a rundown inner city high school. Couple that with sleep deprivation and the need to converse about complex tax jargon, and the whole episode had a bit of a dreamlike quality to it.
I don’t remember either myself or my colleague being particularly persuasive or brilliant in presenting the arguments for our position. The IRS counsel indicated he understood our stance and that he would consider it and send us a final conclusion before year end (The contemplated transaction was scheduled to be triggered January 1, if we had a favorable response).
The quick ending: We received a favorable response from the Service. I had a happy client and one more work war story. The more reflective ending: Man, that was 32 years ago and it seems like yesterday. I left Andersen and evolved out of tax. Andersen folded. That client was absorbed in a larger transaction a decade later.
It is odd what triggers memories; in this case it was the weather. It is humbling to think back on what a tyrant time is. Sometimes you are left to sit in the aftermath of its passing and realize memories and episodes are always there, waiting to be stirred in the pot that mixes the now with the then. I have learned to grant myself grace and relief from thinking too much about the what ifs and the might haves and to embrace the experience of reflection when the then and now collide. Time is not as linear as we think.
I raise a toast to all who travel about in planes, trains, automobiles, or conference calls (I would have gladly met with the IRS on a Zoom call had it been available to me) in service to their career missions; in pursuit of important causes, or at least those that seem important at the time.
I reflect and worry about those without shelter on a day like this. I do something to support them and ask that you consider their plight as well.
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