Robin L. Greenhouse Robin L. Greenhouse

Subscribe to Robin L. Greenhouse's Posts
Robin L. Greenhouse represents businesses and individuals in resolving complex, large-dollar federal tax controversies. Robin is adept at using dispute resolution techniques, including fast track mediation, pre-filing agreements, Internal Revenue Service (IRS) appeals and post-appeals mediation, and has been the lead lawyer in significant litigation. Over her 30-year career as a government and private practice tax litigator, she has argued more than 100 cases in federal courts at every level. Read Robin Greenhouse's full bio.

Law360: US District Court To French Tax Authorities: Pas De Probleme


By and on Mar 15, 2018
Posted In Court Procedure Matters, IRS Guidance, Trial Courts, Uncategorized

Robin Greenhouse and Kevin Spencer recently authored, “US District Court To French Tax Authorities: Pas De Probleme” for Law360. The article discusses a case involving IRS summons and taxpayers’ rights in context of the US-France Treaty. Read the full coverage on Law360.

Continue Reading



Are LB&I’s Campaigns Stuck in the Trenches?


By on Mar 14, 2018
Posted In IRS Appeals, IRS Guidance, Tax Reform, Uncategorized

In January 2017, the Internal Revenue Service (IRS) Large Business & International (LB&I) Division released its announcement related to the identification and selection of its campaigns. The primary purpose of the campaigns was to end the resource intensive continuous audit program (where the LB&I audits a large taxpayer year after year for decades) and a...

Continue Reading



Let’s Get Ready to Rumble – Coca Cola Concentrates on Trial Preparation


By on Feb 20, 2018
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, Transfer Pricing Resource, Trial Courts, Uncategorized

The main attraction in the US Tax Court (Tax Court) is just a few weeks away. On March 5, 2018, The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS) square-off for a much anticipated six-week trial before Judge Lauber. The parties recently filed their Pretrial Memoranda in the case, although the IRS’s memorandum was...

Continue Reading



Expect Controversy in the Wake of Tax Reform


By , and on Feb 7, 2018
Posted In IRS Audits, IRS Guidance, Privilege and Non-Disclosure, Tax Reform, Uncategorized

Tax reform is here to stay (at least for the foreseeable future). The Internal Revenue Service (IRS) may receive additional funds to implement the new tax law. With lowered tax rates, accelerated expensing and forced repatriation of foreign earnings comes an increased risk of an IRS audit. This brave new tax world has left so...

Continue Reading



Facebook Goes to District Court to Enforce Access to IRS Appeals


By and on Nov 13, 2017
Posted In Court Procedure Matters, IRS Guidance, Trial Courts, Uncategorized

On November 8, 2017, Facebook, Inc. and Subsidiaries (Facebook) filed a complaint in the District Court for the Northern District of California asserting that the Internal Revenue Service (IRS) had improperly denied Facebook access to Internal Revenue Service (IRS) Appeals. Facebook’s complaint seeks a declaratory judgment that the IRS unlawfully issued Revenue Procedure 2016-22, 2016-15...

Continue Reading



Tax Court Says IRS’s “Drift-Net” Argument to Expand Privilege Waiver Must Be Anchored in Principles


By , , , and on Nov 3, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Privilege and Non-Disclosure, Trial Courts, Uncategorized

In Estate of Levine v. Commissioner, the US Tax Court (Tax Court) rejected an Internal Revenue Service (IRS) attempt to expand upon the privilege waiver principles set forth in AD Inv. 2000 Fund LLC v. Commissioner. As background, the Tax Court held in AD Investments that asserting a good-faith and reasonable-cause defense to penalties places...

Continue Reading



Read the October Issue of Focus on Tax Strategies & Developments


By , , , , , , , , , and on Nov 1, 2017
Posted In Court Procedure Matters, IRS Guidance, State Controversy, Tax Reform, Tax Refunds, Transfer Pricing Resource, Trial Courts, Uncategorized

The October 2017 issue of Focus on Tax Strategies & Developments has been published. This issue includes five articles that provide insight into US federal and international tax developments and trends across a range of industries, as well as strategies for navigating these complex issues. Republican Leaders Release Tax Reform Framework By David G. Noren Alexander Lee M&A Tax Aspects...

Continue Reading



IRS and Taxpayers Continue to Battle over the IRC Section 199 Deduction for Computer Software


By and on Oct 27, 2017
Posted In IRS Guidance, Uncategorized

On October 20, 2017, the Internal Revenue Service (IRS) published Office of Chief Counsel Internal Revenue Service Memorandum 20174201F (FSA), legal advice written by a field attorney in the Office of Chief Counsel that was reviewed by an associate office, which deals with a merchant bank’s claim that its revenue from merchant discount fees qualifies...

Continue Reading



IRS Guidance Says IRS Can Disclose Confidential Taxpayer Information to Whistleblower with Impunity


By , and on Sep 20, 2017
Posted In IRS Guidance, Uncategorized

Every taxpayer should be aware of the real risk that its own employees could disclose the taxpayer’s confidential and privileged information to the Internal Revenue Service (IRS) for a whistleblower fee. Pursuant to Internal Revenue Code (Code) Section 7623, the IRS is permitted to pay a “whistleblower” who discloses information about a taxpayer who has...

Continue Reading



Senate Attempts to Repeal Chevron Deference


By and on Jul 31, 2017
Posted In Court Procedure Matters, Trial Courts, Uncategorized

In Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. 467 US 837 (1984), the Supreme Court of the United States established a framework for assessing an agency’s interpretation of statutory provisions. First, a reviewing court must ask whether Congress “delegated authority to the agency generally to make rules carrying the force of law,” and...

Continue Reading



STAY CONNECTED

TOPICS

ARCHIVES