Overview


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 over 60 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.

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Results


  • Representing taxpayers in several pending Tax Court cases on Section 199, excise tax, deferred compensation, gift tax, and penalty issues.
  • Representing taxpayers in several IRS administrative matters, including substantial transfer pricing and other international tax issues.
  • US v. Home Concrete & Supply, Supreme Court. Taxpayer victory. In a 5-4 decision, the Supreme Court held that an overstatement of basis was not an omission from income that resulted in a longer statute of limitations, thereby precluding the IRS from assessing any additional taxes or penalties; also represented taxpayers in the Tax Court and Second Circuit on this issue and submitted amicus briefs in the Federal, DC, Fourth, Fifth, Seventh, Ninth and Tenth Circuits.

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Recognitions


  • Chambers USA 2017 – 2019
  • The Legal 500 US, 2017
  • The Legal 500, recognized as a “highly regarded tax litigation lawyer” who “won a significant taxpayer victory in the US Supreme Court

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Community


  • American College of Tax Counsel, Fellow
  • American Bar Association, Section of Taxation:
    • Administrative Practice Committee
    • Court Procedure and Practice Committee
    • Pro Bono & Tax Clinics Committee, Chair (2014 to 2016), Vice-Chair (2013 to 2014)
    • Pro Bono Award Committee (2015 to present)
    • Public Service Fellowship Committee (2014 to 2016)
    • Tax Court Appointments Committee (2015 to present)

Credentials


Education
New York University School of Law, LLM, 2000
Pepperdine University School of Law, JD, cum laude, 1999
University of Washington, BA, 1996

Admissions
California
Illinois

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Andrew R. Roberson

Insights & Events / Media

San Francisco, CA / McDermott Event / December 10, 2019

Tax Executive / September 27, 2019

International Law Office / September 27, 2019

Tax Executive / September 27, 2019

Chicago, Illinois / McDermott Event / September 27, 2018

Chicago, Illinois / Speaking Engagements / March 27, 2018

Chicago, Illinois / McDermott Event / November 16, 2017

Houston, Texas / McDermott Event / November 2, 2017

Washington, District of Columbia / Speaking Engagements / May 11-13, 2017

Law360 / December 20, 2016

Global Tax Weekly (Wolters Kluwer) / August 4, 2016

Tax Notes Today / August 17, 2015

Equitable Tolling and Tax Refund Suits

Effectively Representing Your Client Before the IRS (6th Edition, 2015) / February 2015

Securing Information from Taxpayers by the IRS (Chapter 4)

International Tax Journal / November - December, 2014

Time Limits for Filing Refunds Related to Foreign Tax Credits

The Tax Executive / May- June 2014

The Precedential and Persuasive Value of Unpublished Dispositions

Tax Analysts / April 14, 2014

Lenity and Strict Construction - Overlooked Tools of Construction?

Procedurally Taxing Blog / February 3, 2014

Applying the Rule of Lenity and Strict-Construction Canons in Tax Cases

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