Andrew R. Roberson Andrew R. Roberson

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Andrew (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.

Eighth Circuit Applies Subjective Standard to Reasonable Basis Penalty Defense


By , and on May 4, 2020
Posted In Appellate Courts, Trial Courts, Uncategorized

On April 24, 2020, the US Court of Appeals for the Eighth Circuit published its opinion in Wells Fargo & Co. v. United States, No. 17-3578, affirming a district court’s holdings that the taxpayer was not entitled to certain foreign tax credits and was liable for the negligence penalty for claiming the credits. Much has...

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You Can Now Submit Your Letter Rulings and Determinations to the IRS Electronically


By , and on May 1, 2020
Posted In IRS Guidance, Uncategorized

Rev. Proc. 2020-29 temporarily allows taxpayers to submit certain requests for letter rulings and determinations to the Internal Revenue Service (IRS) electronically. Electronic submissions will be permitted until the revenue procedure is superseded or modified, but taxpayers may still make paper submissions. Electronic submissions are permitted for requests for letter rulings, closing agreements, determination letters,...

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Fifth Circuit Rules that Law Firm Clients’ Identities Are Not Privileged


By , and on Apr 28, 2020
Posted In Appellate Courts, IRS Appeals, Trial Courts, Uncategorized

In Taylor Lohmeyer Law Firm P.L.L.C. v. United States, No. 19-50506, the United States Court of Appeals for the Fifth Circuit held that a Texas-based estate and tax-planning law firm (Firm) could not invoke the attorney-client privilege against an Internal Revenue Service (IRS) summons seeking the identity of its clients. According to an IRS revenue...

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New Revenue Ruling 2020-8 Helps Taxpayers Seek COVID-19 Tax Refund Claims


By , and on Apr 23, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

Recently, in Revenue Ruling 2020-8, the Internal Revenue Service (IRS) announced that it was suspending Revenue Ruling 71-533, which had addressed the interaction of two Internal Revenue Code (IRC) provisions regarding limitations periods on refund claims, pending reconsideration of the holding of the earlier Revenue Ruling. Under IRC section 6511(d)(2)(A), a taxpayer generally must make...

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IRS Flexes Its Administrative Summons Power in Recent Tax Case


By , and on Apr 22, 2020
Posted In Appellate Courts, Tax Refunds, Trial Courts, Uncategorized

The United States Court of Appeals for the Tenth Circuit’s recent opinion in Standing Akimbo, LLC v. United States, No. 19-1049 (10th Cir. April 7, 2020), reminds us of the Internal Revenue Service’s (IRS) ability to obtain the information it needs to examine taxpayers’ returns using its powerful summons tool. In May 2017, the IRS...

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IRS Guidance Signals More Stringent Scrutiny on Transfer Pricing Documentation


By , and on Apr 17, 2020
Posted In IRS Audits, IRS Guidance, Transfer Pricing Resource, Uncategorized

On April 14, 2020, the Internal Revenue Service (IRS) issued informal guidance in the form of frequently asked questions (the “FAQs”), urging taxpayers to strengthen their transfer pricing documentation required under Internal Revenue Code (IRC) section 6662(e) and Treasury Regulations § 1.6662-6. IRC section 6662 provides several types of accuracy-related penalties on underpayments of taxes....

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More Guidance on CARES Act Refund Claims


By , and on Apr 14, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

On April 8, 2020, the Internal Revenue Service (IRS) released a statement telling taxpayers that guidance would be forthcoming on refund claims related to the Coronavirus Aid, Relief and Economic Security Act, or the CARES Act. Consistent with that promise, on April 13, 2020, the IRS issued guidance describing temporary procedures permitting the submission via...

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CARES Act Update: IRS Provides Guidance to Partnerships to Take Advantage of Liquidity Benefits


By , , , and on Apr 13, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

On April 8, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-23 in response to the Coronavirus Aid, Relief and Economic Security (CARES) Act. Rev. Proc. 2020-23 eases restrictions on partnerships’ ability to file amended tax returns and issue amended Schedules K-1 in order for their partners to avail themselves of the retroactive tax relief provided...

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IRS Postpones Virtually All Deadlines Until July 15, 2020, in Response to COVID-19


By , , and on Apr 10, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would have had a filing, payment or other deadline between April 1, 2020, and July 15, 2020, now qualify for an extension. Access the full article.

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CARES Act Refund Claim Guidance


By , and on Apr 10, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

The Coronavirus Aid, Relief and Economic Security Act, or CARES Act, provides tax relief to taxpayers in certain situations. Some of these provisions may generate refunds for prior years, such as the relaxation of restrictions on the use of net operating losses (NOLs) and interest deductions as well as the retroactive availability of additional depreciation...

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