Robin L. Greenhouse
Subscribe to Robin L. Greenhouse's PostsRobin 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.
UTP Filings Continue to Rise
By Kevin Spencer and Robin L. Greenhouse on Oct 12, 2016
Posted In IRS Guidance, Transfer Pricing Resource, Uncategorized
The IRS has released statistics for the 2010 to 2014 tax years relating to Schedule UTP (Uncertain Tax Position) filings, showing that there were 6,320 uncertain tax positions reported in 2014. The statistics show a steady increase in the reported positions, which totaled 4,740 in 2010, although this may also be attributed to the fact...
Continue Reading
Deference Denied to IRS Notice Issued Post-Litigation
By Robin L. Greenhouse on Oct 10, 2016
Posted In IRS Guidance, Trial Courts, Uncategorized
Sometimes a loss in a discovery battle is really a win. That is certainly the outcome in Sunoco, Inc. v. United States, 2016 WL 334578 (Fed. Cl., No. 1:15-cv-00587, 10/6/16). In Sunoco, Judge Wheeler of the Court of Federal Claims denied Sunoco’s motion to compel production of the background file documents for Notice 2015-56 (Aug....
Continue Reading
IRS Updates Rules Regarding Appeals Conferences
By Kevin Spencer, Jean A. Pawlow, Bradford E. LaBonte, McDermott Will & Emery, Robin L. Greenhouse and McDermott Will & Emery on Sep 22, 2016
Posted In IRS Appeals, IRS Guidance, Settlements, Uncategorized
The Internal Revenue Service (IRS) has revised the Internal Revenue Manual (IRM) regarding Appeals Conferences. Below is a summary of material changes to IRM 8.6.1, effective October 1, 2016: The IRM was revised to reflect that most conferences in Appeals will be conducted by telephone. The revision also provides guidance for when in-person conferences are appropriate...
Continue Reading
IRS Wages ‘Campaigns’ against Taxpayers
By Chelsea Hess, Kevin Spencer and Robin L. Greenhouse on Jun 29, 2016
Posted In IRS Appeals, IRS Audits, IRS Guidance, Uncategorized
Late last year, the Internal Revenue Service’s (IRS’s) Large Business and International (LB&I) division announced that it would restructure its organization. The restructuring was precipitated by shrinking resources and a shifting environment. A primary feature of the restructuring is the end of the continuous audit program (where the IRS audits a large taxpayer year after...
Continue Reading
Tax Court Rules in Favor of Medtronic in Transfer Pricing Case Against IRS
By McDermott Will & Emery and Robin L. Greenhouse on Jun 10, 2016
Posted In Court Procedure Matters, Transfer Pricing Resource, Trial Courts, Uncategorized
At least a partial taxpayer victory in the Medtronic case, T.C. Memo. 2016-112. The Tax Court held that Medtronic met its burden of showing the Internal Revenue Service (IRS) abused its discretion by making arbitrary and capricious Internal Revenue Code (IRC) Section 482 reallocations with respect to taxable income of Medtronic’s Puerto Rico subsidiary. It further...
Continue Reading
Two Current Tax Controversies Utilize ‘Quick Peek’ Agreements to Resolve Privilege Disputes
By Joshua M. Ellenberg and Robin L. Greenhouse on May 31, 2016
Posted In Alternative Dispute Resolution, Court Procedure Matters, Privilege and Non-Disclosure, Trial Courts, Uncategorized
Due to the enormous amount of electronic data stored by companies in the modern era, discovery requests can involve millions of documents which need to be reviewed prior to being turned over to the opposing party. In conducting their analysis of this overwhelming quantity of information, litigants must, amongst other things, detect and exclude any...
Continue Reading
IRS Updates Appeals Procedures for Tax Court Cases
By Robin L. Greenhouse and McDermott Will & Emery on Mar 25, 2016
Posted In Alternative Dispute Resolution, Court Procedure Matters, IRS Appeals, IRS Guidance, Settlements, Trial Courts, Uncategorized
On March 23, 2016, the Internal Revenue Service (IRS) issued Rev. Proc. 2016-22, 2016-15 IRB 1, which clarifies and describes the practices for the administrative appeals process in cases docketed in the Tax Court. The stated purpose of the revenue procedure is to facilitate effective utilization of appeals and to achieve earlier development and resolution...
Continue Reading
Generic IRS Publication Fails to Satisfy the Advance Notice Requirement for Third Party Contacts
By Robin L. Greenhouse on Feb 15, 2016
Posted In IRS Audits, Uncategorized
In Baxter v. United States, No. 4:15-cv-04764 (ND Cal. 2016), the Internal Revenue Service (IRS) issued a third-party summons for the petitioner’s 2011 tax year to the California Supreme Court seeking documents relating to payments made to the petitioner for his legal representation of capital defendants. The petitioner brought a timely petition to quash the 2011 third-party...
Continue Reading
