NYU Tax Controversy Forum

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Matthew L. 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, liquidations, and partnership divisions.

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.

For a while now, NYU has held an annual tax controversy forum.  Generally, it is held in-person in New York City.  Of course, this year, the COVID-19 pandemic sidelined the in-person event, but, thankfully, NYU decided to provide the forum free of charge online through webinars.  The forum provides tax professionals a valuable opportunity to hear from top-level government officials on IRS enforcement and collection activities.  This year, although via webinar, was no different.  Some of the more noteworthy discussions included:

IRS Collection Actions.  IRS officials discussed the IRS’ People First Initiative, which has delayed collection action against most taxpayers until July 15, 2020.  When asked about whether collection action would be stayed beyond July 15, 2020, an IRS official indicated this would be determined at a later date.  IRS officials also indicated that they had implemented new procedures for installment agreement requests.  Previously, it was standard procedure for the IRS to refer a case to a Revenue Officer (i.e., to the field) if there was a request for an installment agreement and the aggregate taxes at issue were in excess of $100,000.  Currently, the IRS has increased that amount to $250,000 in an attempt to help taxpayers more easily enter into installment agreements, potentially over the phone.  With respect to offers-in-compromise, the IRS acknowledged that many OICs had not been reviewed yet due to IRS office closures.  However, they indicated that their OIC offices in Brookhaven, New York and Memphis, Tennessee were beginning to slowly open back up again.  The IRS also indicated that they are not sending out failure-to-deposit notices for unpaid employment taxes like they have in the past but that they are currently reviewing whether they should do so after the second quarter of 2020.  The IRS cautioned that the new Forms 7200, Advanced Payment of Employer Credits Due to COVID-19, were being carefully reviewed and would be subject to scrutiny in the future.


State and Local Tax Services 

Freeman Law works with tax clients across all industries, including manufacturing, services, technology, oil and gas, financial services, and real estate. State and local tax laws and rules are complex and vary from state to state. As states confront budgetary deficits due to declining tax revenues and increased government spending, tax authorities aggressively enforce state tax laws to recapture lost revenues. 

At Freeman Law, our experienced attorneys regularly guide our clients through complex state and local tax issues—issues that are frequently changing as states seek to keep pace with technology and the evolution of business. Staying ahead requires sophisticated legal counsel dedicated to understanding the complex state tax issues that confront businesses and individuals. Schedule a consultation or call (214) 984-3000 to discuss your local & state tax concerns and questions.