Update on IRS Enforcement Efforts

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 75 matters at all levels of the federal court system, including the US Tax Court and Federal District Courts, 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. In addition to representing corporations and partnerships in tax disputes, he also represents high net-worth individuals and assists taxpayers needing to make voluntary disclosures. Andy has acted in first- and second-chair roles and been the primary drafter of dozens of pleadings, motions, and briefs. He works closely with personnel in the tax and general counsel departments, as well as with other accounting firm and law firm advisors, in resolving tax disputes. Andy is active in the pro bono community, and has handled more than 25 Tax Court cases for low-income individuals, resulting in opinions on issues of first impression on innocent spouse and penalty issues providing relief to low-income taxpayers nationwide. Andy began his career as an attorney-advisor for Judge Robert P. Ruwe and Joseph R. Goeke of the Tax Court. He is an editor of the Firm’s Tax Controversy 360 blog and Pro Bono Matters for the ABA Tax Times. He is also a frequent author and speaker on tax issues.

Kevin Spencer focuses his practice on tax controversy issues. Kevin represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions. In addition to his tax controversy practice, Kevin has broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters, renewable energy, state and local tax, and private client matters. After earning his Master of Tax degree, Kevin had the privilege to clerk for the Honorable Robert P. Ruwe on the US Tax Court. Kevin is a prolific writer and lecturer on a variety of tax topics, and is an active member of the Firm’s Pro Bono and Community Service Committee. He is also an adjunct law faculty member at Georgetown University Law Center and is an editor of the Firm’s Tax Controversy 360 blog.