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.
National Taxpayer Advocate’s Report Highlights Tough Times for Tax Administration
By Andrew R. Roberson and Kevin Spencer on Jan 18, 2022
Posted In Alternative Dispute Resolution, IRS Audits, IRS Guidance, Tax Reform, Tax Refunds
On January 12, 2022, the National Taxpayer Advocate released a report to US Congress concerning the state of tax administration in 2021. The report highlights the struggles the Internal Revenue Service (IRS) has been having in the wake of the COVID-19 pandemic, including how the IRS is substantially behind in processing returns, the breakdown of...
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Extending the Statute of Limitations for Assessing Federal Tax
By Andrew R. Roberson and Kevin Spencer on Jan 14, 2022
Posted In IRS Audits, Tax Reform, Tax Refunds
We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date of the original tax return or the date it was filed. If the IRS does...
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A Sit-Down with Andrew VanSingel
By Andrew R. Roberson on Jan 12, 2022
Posted In Uncategorized
Andrew Roberson interviewed Andrew VanSingel, who dedicated his career to providing pro bono and public services to low-income taxpayers, for an American Bar Association Pro Bono Matters column. They discussed VanSingel’s work in the disaster relief area and at TAS, shared advice for young lawyers who want to get more involved in pro bono work...
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Tax Court Opinions Are Searchable (Again)
By Andrew R. Roberson and Kevin Spencer on Dec 29, 2021
Posted In Court Procedure Matters, Trial Courts
The US Tax Court gave taxpayers and tax practitioners a belated Christmas gift when it announced that the Opinion search feature is back. This news comes on the heels of the Tax Court’s reintroduction of the Order search function earlier this month. The Opinion search function allows the public to search for specific cases by...
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Types of Tax Court Opinions and Their Precedential Effect (Updated)
By Andrew R. Roberson and Kevin Spencer on Dec 20, 2021
Posted In Court Procedure Matters, Trial Courts
At the end of 2016 we posted “Types of Tax Court Opinions and Their Precedential Effect” and added that document to the Resources tab on the blog. We recently updated this resource and, below, we’ve also provided the updated text. Most tax cases are decided by the US Tax Court, which issues two categories of...
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Omitted Subpart F and GILTI Income May Be a Statute of Limitations Trap for the Unwary
By Andrew R. Roberson and Kevin Spencer on Dec 17, 2021
Posted In IRS Guidance, Tax Reform
Taxpayers large and small desire closure with respect to tax reporting positions. This can occur in several ways, one of which is the closing of the limitations period for assessing additional tax. In this article published in the November-December 2021 issue of the International Tax Journal, McDermott Partners Andrew R. Roberson and Kevin Spencer discuss...
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An Overview of IRS Organization and Operations
By Andrew R. Roberson and Kevin Spencer on Dec 16, 2021
Posted In IRS Guidance
McDermott’s Federal Tax Controversy Practice Group focuses on representing taxpayers in tax disputes with the Internal Revenue Service (IRS) in IRS examinations and IRS administrative appeals as well as litigation in federal trial and appellate courts. In resolving such disputes, it is helpful for taxpayers (and tax practitioners) to understand how the IRS operates as...
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Tax Court Orders Are Searchable (Again)
By Andrew R. Roberson and Kevin Spencer on Dec 15, 2021
Posted In Trial Courts
In late 2020, the US Tax Court transitioned to a new case management system, DAWSON (Docket Access Within a Secure Online Network), which was named after the late Judge Howard A. Dawson, Jr.. We previously discussed DAWSON here and here. Over the past year, the Tax Court has made improvements to DAWSON in order to...
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Tax Court Selects Two New STJs
By Andrew R. Roberson and Kevin Spencer on Dec 8, 2021
Posted In Trial Courts
On December 6, 2021, the US Tax Court announced that Adam B. Landy and Eunkyong Choi have each been selected to serve as Special Trial Judges (STJs). They join the existing members of the Tax Court, which include four other STJs, 17 presidentially appointed Judges, and 10 Senior Judges serving on recall. STJ Landy was...
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Special Trial Judge Receives Tax Court’s Highest Award
By Andrew R. Roberson and Kevin Spencer on Nov 23, 2021
Posted In Trial Courts, Uncategorized
On November 21, 2021, the US Tax Court announced that Special Trial Judge Daniel A. Guy, Jr., received the J. Edgar Murdock Award for his distinguished service to the Tax Court. The Murdock Award commemorates Judge John Edgar Murdock, who served on the Tax Court from 1926 to 1968 and has been described as probably...
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