Cindy Wofford

Cindy Wofford

Cindy Wofford joined Freeman Law as Senior Counsel in 2022. Ms. Wofford brings to the firm over 40 years of tax controversy and estate planning/probate experience, 20 years with the IRS’s Office of Chief Counsel in Washington, D.C. and Dallas; the remainder with firms in Washington, D.C., Dallas, and Houston.

IRS Counsel’s National Office is charged with formulating the IRS’s litigating position in cases pending before federal courts. As a National Office attorney, Ms. Wofford primarily focused on collection due process litigation policy and strategy. The tax code requires the IRS to follow certain laws and procedures prior to filing a notice of federal tax lien or issuing a levy to collect a taxpayer’s unpaid taxes. “CDP” allows certain delinquent taxpayers to test whether the IRS followed these laws and procedures in Tax Court. Among her National Office functions, Ms. Wofford reviewed briefs, motions and memoranda to be filed with the Tax Court in CDP cases. She drafted sections of the first CDP Guidebook. She also prepared and reviewed published and internal guidance relating to liens, levies and other collection issues.

Ms. Wofford left the  IRS Counsel’s National Office for its Small Business/Self-Employed (SB/SE) Dallas office. While in SB/SE, Ms. Wofford handled over 840 docketed Tax Court cases, from case analysis and development to trial and briefing or settlement. Ms. Wofford also served as a CDP resource to SB/SE attorneys and appeals officers in and out of Texas for 18 years. She participated regularly in internal/external attorney and CDP settlement officer trainings at the local, regional and national levels.

Prior to her government service, Ms. Wofford practiced in private firms, focusing on estate planning and probate and family law. Ms. Wofford drafted premarital and marital agreements, wills, and trusts, advised clients on divorce-related tax issues, and she represented clients seeking innocent spouse relief before the IRS. She handled the administration of estates ranging from small estates to estates in excess of $10 million. Ms. Wofford was also active in the ABA Tax Section, serving as chair and vice-chair of the Domestic Relations Committee. During this time, she was the committee’s liaison with the IRS.

While in private practice, Ms. Wofford wrote extensively for various legal publications. Ms. Wofford is the author of the Tax Management portfolios, Divorce and Separation, TM 515 and 5152nd, treatises on tax laws and cases affecting divorced and divorcing taxpayers.

Ms. Wofford earned a J.D. from the University of Texas School of Law and a LL.M (Taxation) from Southern Methodist University School of Law.

 

Federal Tax litigation Attorney, Matthew Roberts

Matthew L. Roberts

Mr. Roberts is a Principal of the firm. He devotes a substantial portion of his legal practice to helping his clients successfully navigate and resolve their federal tax disputes, either administratively, or, if necessary, through litigation. As a trusted advisor he has provided legal advice and counsel to hundreds of clients, including individuals and entrepreneurs, non-profits, trusts and estates, partnerships, and corporations.

Having served nearly three years as an attorney-advisor to the Chief Judge of the United States Tax Court in Washington, D.C., Mr. Roberts leverages his unique insight into government processes to offer his clients creative, innovative, and cost-effective solutions to their tax problems. In private practice, he has successfully represented clients in all phases of a federal tax dispute, including IRS audits, appeals, litigation, and collection matters. He also has significant experience representing clients in employment tax audits, voluntary disclosures, FBAR penalties and litigation, trust fund penalties, penalty abatement and waiver requests, and criminal tax matters.

Often times, Mr. Roberts has been engaged to utilize his extensive knowledge of tax controversy matters to assist clients in their transactional matters. For example, he has provided tax advice to businesses on complex tax matters related to domestic and international transactions, formations, acquisitions, dispositions, mergers, spin-offs, and liquidations.

In addition to federal tax disputes, Mr. Roberts has represented clients in matters relating to white-collar crimes, estate and probate disputes, fiduciary disputes, complex contractual and settlement disputes, business disparagement and defamation claims, and other complex civil litigation matters.

Mr. Roberts received his Bachelor of Accountancy and his Master of Science in Taxation from the University of Mississippi. He received his law degree, summa cum laude, from the University of Mississippi School of Law, where he graduated in the top five percent of his law school class. During law school, he was an editor for the Mississippi Law Journal and also an executive board member of the Moot Court Board.

After law school, he received an LL.M. (Master of Laws) in Taxation from New York University School of Law. He is a frequent speaker and author on complex tax matters, and his articles have been published in national and regional publications including the Journal of Tax Practice and Procedure, Tax Notes, and The Tax Adviser.

Speaking Engagements

  • “Coronavirus Relief: The PPP and the New Loan Forgiveness Guidance,” CPA Academy Webinar, May 21, 2020.
  • “IRS Collection Representation in the Wake of COVID-19,” CPA Academy Webinar, April 30, 2020.
  • “COVID-19 Deep Dive,” TXCPA Webinar, April 13, 2020.
  • “Coronavirus and Recent Tax and Business Relief: What You Need to Know Now,” TXCPA Dallas Webinar, April 8, 2020.
  • “Coronavirus and Recent Tax and Business Relief: What You Need to Know Now,” Dallas Bar Association Webinar, April 7, 2020.
  • “Partnership Tax Audit and Collection Rules Including Final and Reproposed Regulations,” 2019 Corpus Christi Chapter/TSCPA Tax Conference, February 1, 2019.
  • “New Partnership Audit Rules: What They Mean to Partnerships and Tax Professionals,” Lorman Live Webinar, March 16, 2018.
  • “New Partnership Audit Rules: What They Mean to Partnerships and Tax Professionals,” Dallas Bar Association Tax Section, December 4, 2017.
  • “The New Partnership Audit Rules,” First Bank & Trust Seminar, November 9, 2016.
  • “Taxing Times: Planning and Defending in an Uncertain Tax and IRS Environment,” Firm Conference, October 25, 2016.
  • “Civil and Criminal Employment Tax Enforcement Efforts: Employers Beware,” Firm Conference, November 3, 2015.

Representative Matters

  • Represented numerous clients in obtaining full abatement or waiver of trust fund recovery penalties.
  • Represented various clients in obtaining full abatement or waiver of federal tax penalties, including failure-to-file and failureto-pay penalties and international reporting obligation penalties including Forms 5471, 5472, 3520, 3520-A, 8938, and FBAR
  • Filed petitions and litigated over 30 cases in the United States Tax Court
  • Represented innocent spouses in obtaining full innocent spouse relief under I.R.C. § 6015.
  • Represented clients in Collection Due Process (CDP) hearing matters, including representation at the IRS Independent Office of Appeals and at the United States Tax Court.
  • Counseled clients on unfiled tax return matters including preparation and submissions of Offshore Voluntary Disclosure Program (OVDP) materials, Streamlined Filing Compliance Procedure materials, and other voluntary disclosure programs.
  • Represented numerous non-profits with respect to IRS examination for proposed self-dealing penalties and other applicable non-profit penalties.
  • Counseled various clients on IRS collection alternatives, resulting in significant reductions in tax debts for clients due to successful submissions of offers-in-compromise.
  • Senior associate in False Claims Act and Anti-Kickback Statute qui tam health care fraud lawsuit, U.S. ex rel. Dean v. Paramedics Plus, LLC, et al., No. 4:14-CV-203 (E.D. Tex.), where Government sought damages in excess of $300 million against client.
  • Lead counsel in will and probate contest, resulting in over $1.5 million settlement award for client.
  • Prepared complex tax opinions and provided tax advice to clients on tax effects of litigation settlement and judgment awards.
  • Provided legal counsel to clients on tax effects and structuring of domestic and international business transactions, including formations, acquisitions, dispositions, mergers, spin-offs, and liquidations.
  • Advised clients with international business operations on I.R.C. § 951A GILTI inclusion and recommended various courses of action including I.R.C. § 962 election or use of corporate blocker.
  • Successfully represented client in FBAR federal district court litigation.
  • Provided legal counsel to numerous clients in structuring tax-free partnership divisions and tax-free corporate spin-offs.
  • Represented client in disputed Irrevocable Life Insurance Trust (ILIT) in IRS Independent Office of Appeals, resulting in federal estate tax savings in excess of $1 million.
  • Represented client in federal gift tax dispute with IRS, resulting in federal gift tax savings in excess of $500,000.
  • Represented clients in IRS “eggshell” audits, resulting in no criminal referrals.
  • Represented numerous clients where IRS sought to classify horse, cattle, and farming activities as hobby losses under I.R.C. §
    183.
  • Provided legal counsel to clients on deferred compensation arrangements under I.R.C. § 409A.
  • Analyzed and provided legal advice on Buy-Sell Agreement for purchase of approximately $10 million company.
  • Provided legal advice on tax effects of the sale of intangible property, including copyrights, trademarks, goodwill, and patents.
  • Prepared organizational documents and tax-exempt status applications for non-profit entities.
  • Defended clients with respect to disputed employment classifications (employee vs. independent contractor) before the IRS and Texas Workforce Commission.
  • Provided legal advice to clients and CPAs on new centralized partnership audit regime under Bipartisan Budget Act (BBA) of 2015.
  • Provided legal advice to client on tax effects of certain oil and gas drilling activities in the State of Texas.
  • Provided legal advice to numerous clients on federal withholding and reporting obligations with respect to certain outbound transactions.
  • Counseled clients with respect to tax effects of Foreign Investment in Real Property Tax Act (FIRPTA).
  • Assisted clients in various tax free-reorganizations, both foreign and domestic, including those under I.R.C. § 368(a)(1)(A)
    (statutory mergers or consolidations); I.R.C. § 368(a)(1)(B) (stock-for-stock); I.R.C.§ 368(a)(1)(C) (stock-for-asset); I.R.C. §
    368(a)(1)(D) (divisions); and I.R.C. § 368(a)(1)(F) (reorganizations).
  • Represented clients in obtaining full abatement or waiver of information return reporting penalties, such as Forms W-2,
    Forms W-3, and Forms 1099.
  • Represented oil and gas pipeline company in employment tax audit, resulting in significant reductions in employment tax and
    employment tax penalties.
  • Represented cryptocurrency client with respect to purported failure to follow FinCEN anti-money laundering statutes.
  • Prepared sentencing memo for client accused of criminal tax evasion, resulting in probation and no jailtime for client.

Download Mr. Roberts' CV

    • University of Texas School of Law
    • Southern Methodist University School of Law