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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Recognition


  • Chambers USA 2017, 2018
  • 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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