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. Professionally licensed as an attorney for more than a decade, Mr. Roberts 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 recovery 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 including allegations of fraud.
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 Practice and Procedure, Tax Notes, The Tax Advisor, and Today’s CPA.
Mr. Roberts has also served as a tax law professor at the Southern Methodist University Dedman School of Law, where he taught Corporate Income Taxation.
Lead counsel in estate and probate litigation resulting in over $1.5 million settlement award for client.
Successfully represented client in obtaining over $900,000 of innocent spouse relief under section 6015 of the Code.
Successfully represented clients in obtaining settlement with the IRS resulting in reduction of over $750,000 in proposed federal income taxes, late-filing penalties, and accuracy-related penalties.
Obtained over $300,000 in trust fund recovery penalty abatements through settlement negotiations with the IRS.
Obtained full concession from IRS in employment tax audit on basis that employer qualified under Section 530 resulting in no additional employment taxes or penalties post-examination.
Represented estate in obtaining abatement of over $400,000 of civil penalties for late-filing, late-payment, and failure-to-make-estimated-tax-payment penalties.
Co-counsel in significant issues of first impression before district courts in Fifth Circuit Court of Appeal and D.C. Circuit Court of Appeal regarding scope of the Anti-Injunction Act and constitutionality of passport revocation statute under section 7345 of the Code.
Counsel in over 83 docketed United States Tax Court cases.
Represented hundreds of clients in submitting disclosures to the IRS.
Successfully represented client in obtaining IRS administrative abatement of $100,000 Form 3520 penalty under section 6039F of the Code.
Represented non-profit client and successfully invoked statute of limitations defense to $100,000 self-dealing penalty resulting in full concession of penalty.
Authored complex tax opinions and provided tax advice on matters including those relating to the taxability of settlement awards and judgments and the deductibility of attorneys’ fees.
Represented clients in Collection Due Process (CDP) hearing matters, including representation before the IRS Independent Office of Appeals.
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