Andrew R. Roberson
Subscribe to Andrew R. Roberson's PostsAndrew (Andy) R. Roberson focuses his practice on tax controversy and litigation matters. He represents clients before the Internal Revenue Service (IRS) Examination Division and Appeals Office and has been involved in more than 50 matters at all levels of the federal court system, including the US Tax Court, several US courts of appeal and the Supreme Court. Andy has experience settling tax disputes through alternative dispute resolution procedures, including Fast Track Settlement and Post-Appeals Mediation, and in representing clients in Compliance Assurance Process (CAP) audits. He also represents individuals in Global High Wealth Industry Group audits and in connection with offshore disclosure programs. Read Andy Roberson's full bio.
IRS Issues Practice Unit on Section 965 Transition Tax
By Andrew R. Roberson and Kevin Spencer on Mar 24, 2021
Posted In IRS Audits, IRS Guidance, Tax Reform
One of the most pressing audit issues for large taxpayers today centers on the Internal Revenue Code (Code) Section 965 transition tax. The Internal Revenue Service (IRS) has designated Code Section 965 as a campaign issue and is actively auditing taxpayers’ transition tax calculations and positions, along with other tax reform items. The stakes are...
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Exxon Prevails in $200 Million Tax Penalty Case
By Andrew R. Roberson and Kevin Spencer on Jan 26, 2021
Posted In Appellate Courts, IRS Appeals, Settlements, Tax Refunds, Trial Courts
On January 13, 2021, the US District Court for the Northern District of Texas ruled in favor of Exxon Mobil Corporation (“Exxon”) in its battle against the government over tax penalties. Exxon filed amended returns for its 2006-2009 tax years seeking a $1.35 billion tax refund based upon a change of character of certain transactions...
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Let’s All Stop and Reflect for a Moment
By Andrew R. Roberson on Dec 21, 2020
Posted In Appellate Courts, Tax Reform, Trial Courts
In a recent article for the American Bar Association’s ABA Tax Times, McDermott partner Andrew R. Roberson reflected on 2020 and the importance of giving back. “From COVID-19 to the Black Lives Matter movement; from home office and Zoom to remote learning for students; and so on—these events have impacted us all, both on professional...
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Tax Court Announces New Case Management System to Go Live Before New Year’s
By Andrew R. Roberson and Kevin Spencer on Dec 18, 2020
Posted In Court Procedure Matters, Trial Courts
We previously reported on the US Tax Court’s (Tax Court) announcement that it was changing its case management system, DAWSON (Docket Access Within a Secure Online Network). This morning, the Tax Court issued a press release confirming the launch of DAWSON on December 28, 2020. Temporary credentials for taxpayers and practitioners already registered for electronic...
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2020’s Key Tax Controversy Developments
By Andrew R. Roberson and Kevin Spencer on Dec 16, 2020
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, IRS Audits, IRS Guidance, Transfer Pricing Resource, Trial Courts
In the face of the pandemic and all the challenges that came with 2020, tax controversy marched on. In this article, we explore several important cases, including one of the most closely watched Supreme Court cases, CIC Services LLC v. Internal Revenue Service, which raises important questions regarding the scope of the Anti-Injunction Act and...
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The End of an Era—Senior Judge Robert P. Ruwe Retires from US Tax Court
By Andrew R. Roberson and Kevin Spencer on Dec 3, 2020
Posted In Court Procedure Matters, Trial Courts
The US Tax Court (Tax Court) recently announced that Senior Judge Robert P. Ruwe has fully retired as of November 25, 2020, after more than 33 years on the bench. Judge Ruwe graduated from Xavier University and was first in his class in law school at the Salmon P. Chase College of Law. He then...
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Tax Court to Update Case Management System
By Jenny L. Johnson Ware, Andrew R. Roberson and Kevin Spencer on Oct 22, 2020
Posted In Court Procedure Matters, Trial Courts
The US Tax Court (Tax Court) recently announced upcoming changes to its case management system. DAWSON (Docket Access Within a Secure Online Network), named after former Tax Court Judge Howard A. Dawson, Jr., who passed away in 2016, is expected to be active by the end of 2020. To facilitate the transition to DAWSON, the...
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Skip Jail and Clean Up Your Tax Problems
By Jenny L. Johnson Ware, Andrew R. Roberson, Kevin Spencer and Le Chen on Jul 16, 2020
Posted In IRS Appeals, IRS Audits, IRS Guidance, Tax Reform
If you have knowingly failed to report income or claimed deductions you know you are not entitled to, or just decided not to file your tax returns and pay the tax owed, you may be liable for civil penalties and even jail time for criminal tax evasion. Taxpayers with civil and criminal tax exposure may...
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Section 965 Statutes of Limitations for Partnerships
By Andrew R. Roberson, Kevin Spencer and Robbie Alipour on Jun 29, 2020
Posted In IRS Audits, IRS Guidance, Tax Reform
On May 26, 2020, the Internal Revenue Service (IRS) issued PMTA 2020-08 to provide guidance on the period of limitations for Internal Revenue Code (IRC) section 965, transition tax-related adjustments of partnerships. Typically, pursuant to IRC section 6501, the IRS has three years to assess a tax liability for a tax year. However, IRC section...
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IRS Targets Private Foundations That May Be Used by Wealthy Taxpayers in Tax Planning
By Andrew R. Roberson, Kevin Spencer and Brian Moore on Jun 26, 2020
Posted In IRS Audits, IRS Guidance, Tax Reform, Tax Refunds
In remarks at the NYU Tax Controversy Forum on June 18, 2020, Internal Revenue Service (IRS) officials indicated that the agency is analyzing the use of private foundations for tax planning. Ms. Tamera Ripperda, who is the commissioner of the Tax Exempt and Government Entities (TEGE) Division and previously served as the industry director for the Global...
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