May 15, 2025
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar and Government Regulatory Litigation, Income Tax and Business Planning, and Cryptocurrency and Digital Assets. He is Board Certified in Tax Law by the Texas Board of Legal Specialization. Mr. Roberts is a tax litigator and trusted advisor with extensive experience assisting both U.S. and international clients in successfully resolving various federal tax controversies, including civil and criminal liability cases. His expertise covers a broad spectrum of issues, such as tax audits, investigations, litigation, appeals, and collection matters.
Mr. Roberts served three years as an attorney-advisor to the Chief Judge of the U.S. Tax Court in Washington, D.C. This opportunity provided him with the knowledge and ability to understand complex government processes and develop innovative, cost-effective solutions for his clients' tax challenges.
He has acted as counsel of record in numerous U.S. Tax Court cases, representing clients in controversies that range from $100,000 to over a $100 million. His diverse client list includes high-wealth individuals, entrepreneurs, non-profits, trusts and estates, partnerships, and corporations in various industries.
Clients depend on Mr. Roberts for guidance on best practices to prevent or minimize the financial and criminal repercussions of government tax inquiries. He manages various tax compliance and reporting matters, such as preparing voluntary disclosures to address unfiled or incorrect tax returns, advising on international tax reporting and penalties, and providing opinions on the tax implications of significant financial events like lawsuit judgments, settlements, and theft or other tax losses.
Mr. Roberts is frequently sought after as a speaker and author on a wide range of tax topics. He has published articles in national and regional publications, including the Journal of Practice and Procedure, Tax Notes, The Tax Adviser, Wolters Kluwer, Law360, and Today’s CPA. He regularly contributes articles to Forbes, focusing on tax litigation, tax fraud, and foreign reporting tax matters.
Mr. Roberts has served as a tax law professor teaching Corporate Income Taxation at Southern Methodist University Dedman School of Law.
- New York University School of Law, LL.M. in Taxation
- The University of Mississippi School of Law, J.D., summa cum laude
- Associate Mississippi Cases and Staff Editor, Mississippi Law Journal
- Executive Board, Ole Miss Moot Court Board
- The Order of the Barristers
- The University of Mississippi, M.S., Taxation
- The University of Mississippi, B.S., Accountancy
- American Bar Association
- Section of Taxation
- State Bar of Texas
- Tax Section
- Vice-Chair, Tax Controversy Committee (2024-present)
- Dallas Bar Association
- Tax Section
- State Bar of Mississippi
- Tax Section
- Texas, 2015
- Mississippi, 2011
- United States Supreme Court
- United States Tax Court
- United States Court of Appeals , Fifth Circuit
- United States District Court, Northern District of Texas
- United States District Court, Eastern District of Texas
- United States District Court, Southern District of Texas
- United States District Court, Western District of Texas
- The Best Lawyers in America®, 2025, Tax Law
- Co-Author, “Buckle Your Seatbelts: Employment Taxes are Back in Vogue and It Will Be a Bumpy Ride—The IRS and Department of Justice Tax Division are on the Hunt”, Journal of Tax Practice and Procedure, June-July 2015
- Co-Author, "The New Partnership Audit Rules—Turning the Taxation of Partnerships Upside Down," Petroleum Accounting and Financial Management Journal, Summer 2016.
- "New IRS Tax Audit Rules and Divorce Agreements", Dallas Bar Association Headnotes: Family Law, September 2018
March 26,2025
IRS Confirms Some Internet Theft Losses Are Permitted Post-TCJA But Risks Remain... [ read ]
Fraud and theft continue to rise in the United States. According to a recent FTC report, Americans lost more than $12.5 billion from fraud in 2024 (an increase of 25% from the prior year). The FBI confirmed the upward trend in early 2024, noting "an alarming increase[ ] in both the frequency and financial impact of online fraud perpetrated by cybercriminals."
March 20, 2025
IRS Chief Counsel Finds Foot Fault on BBA Statute of Limitations... [ read ]
In tax controversy and litigation matters, sometimes procedure trumps the merits of a case. The statute of limitations is a great example. Even if the taxpayer made a mistake on a prior year return, the IRS generally can't open an audit if the applicable statute of limitations period has expired. The Bipartisan Budget Act of 2015 (BBA) has its own statute of limitations rules associated with partnerships.
February 26, 2025
Meadows Collier Partners Submit Comments on Proposed Revisions to Circular 230... [ read ]
Firm partners Jeffrey M. Glassman and Matthew L. Roberts, through their respective leadership positions with the State Bar of Texas Tax Section (Tax Section), recently submitted comments to the Treasury and IRS on proposed revisions to Circular 230. Mr. Glassman serves as the Chair of the Tax Controversy Committee for the Tax Section, and Mr. Roberts serves as the committee's Vice Chair.
March 21, 2018
IRS Nixes Popular Offshore Voluntary Disclosure Program... [ read ]
On March 13, 2018, the Internal Revenue Service (IRS) announced that it will terminate its 2014 Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018. Since its launch in 2009, over 56,000 taxpayers have taken advantage of the program and its potential shield from criminal tax liability for the willful failure to report and pay tax on foreign accounts
July 25, 2017
MLR Blog Post- U.S. Tax Court Decision Deals Blow to IRS on Taxation of U.S. Partnership Interests Held by Foreign Persons... [ read ]
At last year's Annual Meadows Collier Tax Conference, my colleague, Stephen Beck, and I discussed some of the more recent hot topics in international tax law. During our discussions, we spoke of the current ambiguity in U.S. tax law as it relates to the sale of a U.S. partnership interest by a foreign person. For decades, the IRS has argued that the sale of such partnership interests should be subject to U.S. tax if the partnership was engaged in a U.S. trade or business. See Rev. Rul. 91-32, 1991-1 C.B. 107.
March 1, 2017
Federal District Court Holds that Taxpayer Showed Reasonable Cause for Abatement of Late-Filing Penalties in Relying on a Tax Professional... [ read ]
For a multitude of reasons, the late-filing penalty has remained a priority of the IRS. First, the late-filing penalty is easy for the IRS to police through the use of modern computer systems which automatically identity and impose the penalty after a return has been filed late. Second, the amount of the penalty, or 25% of the net tax due after only five months, represents an easy windfall of revenue to the Government. Third, imposition of the late-filing penalty naturally deters taxpayers from filing their returns late and promotes compliance with the tax system. Fourth, attempts by taxpayers to have the penalty waived or abated—termed "reasonable cause" in tax parlance—require an affirmative showing of relief upon which the taxpayer bears the burden of proof.
August 12, 2016
Existing Oil Tax Credit Available for First Time in a Decade... [ read ]
Since 2006, the enhanced oil recovery credit ("EORC") has been unavailable to taxpayers who operate in the energy sector. However, recent reductions in the realized prices of oil have once again made the EORC relevant for tax year 2016.
July 19, 2016
IRS Begins Accepting Applications for Certified Professional Employer Organizations (CPEOs)... [ read ]
In a previous blog post , I generally discussed passage of the Tax Increase Prevention Act of 2014 ("TIPA") and its overall positive impact on employers who relied on the services of professional employment organizations ("PEOs") for payroll processing and employment tax payments.
May 2, 2016
The Clock is Ticking: U.S. Government Officials Investigate Panama Papers... [ read ]
Panama has long been known as a favorite country for many taxpayers on account of its low tax rates and strict confidentiality laws, the latter of which serve to protect the identities of Panamanian corporate shareholders and bank account holders in the case of frivolous civil litigation. Accordingly, it should come to no one's surprise that many non-Panamanian citizens take advantage of these low rates and confidentiality laws by creating Panamanian entities and utilizing the Panamanian banking system. Until recently, no one really knew how prolific the use of these entities was by non-Panamanian citizens or the extent to which they may be used by persons to avoid detection by taxing authorities and other governments. However, on April 3, 2016, the world got a glimpse of all of the above when a treasure trove of business records and documents relating to the formation and operation of Panamanian companies was released by hundreds of journalists from across the globe.
December 22, 2015
Think the IRS Can't Audit You After 3 Years? Think Again.... [ read ]
There is perhaps no worse a feeling to taxpayers than when they receive an IRS notice indicating their return has been selected for examination. Thankfully, Congress has placed substantial limitations on the IRS' ability to examine returns and assess additional tax: a 3-year statute of limitations period. Under the general statute of limitations period, the IRS has three years after the return is filed to assess any additional tax. See I.R.C. § 6501(a).
September 17, 2015
It's About Time - Slowly But Surely the IRS Finally Agrees to Let Employers Off the Hook When They Use a Professional Employer Organization (PEO)... [ read ]
According to the National Association of Professional Employer Organizations, approximately 2 to 3 million people are currently covered under a PEO arrangement. After TIPA is fully implemented, with many provisions effective January 1, 2016, expect these numbers to increase in the coming years.
August 10, 2015
The IRS Has Issued You a Notice of Tax Lien, Now What?... [ read ]
After a taxpayer fails to remit payment on an outstanding tax liability and the IRS issues a demand for payment, the Internal Revenue Code imposes a statutory lien in favor of the government on all property and property rights of the taxpayer. I.R.C. § 6321. The lien dates back to the date of assessment and continues until the liability is satisfied or becomes unenforceable. I.R.C. § 6322.
May 6, 2015
IRS Issues Notice 2015-38... [ read ]
With release of Notice 2015-38, 2015-21 I.R.B. 21, effective May 6, 2015, the Internal Revenue Service has provided an updated list of private mail carriers taxpayers may use to qualify under the timely-mailed-timely filed provisions of section 7502 (i.e., the mailbox rule). As discussed more fully below, taxpayers mailing documents or payments by private mail carrier are well-advised to understand fully the implications and requirements of this notice.
