Mr. Roberts is a senior associate in the firm and focuses his practice in the areas of Income Tax Litigation and Estate and Gift Tax Litigation. His practice also includes White Collar and Government Regulatory Litigation, State Tax Planning and Litigation, and domestic and international Income Tax and Business Planning.
Mr. Roberts has experience representing clients in all phases of an IRS dispute including audits, administrative appeals, collections and litigation. He has handled cases in a number of different subject matters, such as employment tax audits, voluntary disclosures, FBAR penalties and litigation, cross-border refund claims and U.S. tax withholding obligations, tax-exempt entity audits, and penalty abatement and waiver requests. Mr. Roberts also has experience in criminal tax matters.
Mr. Roberts was admitted to practice law in Texas in 2015 and in Mississippi in 2011. From 2012 through 2015, Mr. Roberts was an Attorney-Advisory for The Honorable Chief Judge Michael B. Thornton of the United States Tax Court in Washington D.C. He is a frequent writer and speaker on the new centralized partnership audit regime.
- New York University School of Law, LL.M. in Taxation, 2012
- The University of Mississippi School of Law, J.D., summa cum laude, 2011
- Associate Mississippi Cases and Staff Editor, Mississippi Law Journal, 2009-2011
- Executive Board, Ole Miss Moot Court Board, 2010-2011
- The Order of the Barristers
- Mississippi Bar Foundation Scholarship
- Mississippi Bar Real Property Scholarship
- Dean’s Leadership Council
- Outstanding Student Award (Contracts II, Intellectual Property/Antitrust)
- Phi Kappa Phi
- Published, Transmuting Mississippi’s Current Transmutation Doctrines: Establishing Clear and Consistent Precedents to Property Division, 80 MISS. L.J. 709 (2010)
- The University of Mississippi, Masters of Taxation, 2008
- The University of Mississippi, Bachelor of Accounting, 2006
- Beta Gamma Sigma
- Beta Alpha Psi
- American Bar Association
- Section of Taxation
- State Bar of Texas
- Tax Section
- Dallas Bar Association
- Tax Section
- State Bar of Mississippi
- Tax Section
- Dallas Association of Young Lawyers
- Supreme Court of Mississippi
- United States Court of Appeals for the Fifth Circuit
- United States District Court for the Eastern District of Texas
- United States District Court for the Northern District of Texas
- United States Tax Court
- 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.
DBA Family Law Section... [ read ]
Lorman Live Webinar... [ read ]
Dallas Bar Association Tax Section... [ read ]
SMU Career Foundations and Professional Development Series... [ read ]
First Bank & Trust Seminar... [ read ]
18th Annual Meadows Collier Tax Conference... [ read ]
2015 Meadows Collier Taxation Conference... [ read ]
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
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.
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.
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.
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.
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.
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).
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.
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.
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.