Matthew  Roberts
Partner

Clients hire me when they need a seasoned tax litigator and creative problem-solver who will bring unique perspectives to the case, explore every available option, and find the most effective and cost-efficient path to achieving their goals.

Matt Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients successfully resolve all types of federal tax controversies involving civil or criminal liability, from tax audits and investigations to litigation, appeals and collection matters. Having served nearly three years as an attorney-advisor to the Chief Judge of the U.S. Tax Court in Washington, D.C., Matt brings unique insight to navigating intricate government processes and developing innovative and cost-effective solutions to his clients’ tax problems. His client list spans many industries and ranges from individuals and entrepreneurs to non-profits, trusts and estates, partnerships and corporations. 

Clients also rely on Matt to advise on best practices for preventing or minimizing the financial and criminal impact of government tax inquiries. He handles a variety of tax compliance and reporting matters, including preparing voluntary disclosures to remedy unfiled or incorrect tax returns, advising on international tax reporting and penalties, and preparing opinions on the tax consequences of major financial events such as lawsuit judgments and settlements and theft or other tax losses. 

As a respected thought leader on complex tax matters, Matt is in high demand as a speaker and author on a wide range of topics. His articles have been published in national and regional publications such as the Journal of Practice and Procedure, Tax Notes, The Tax Adviser, Wolters Kluwer and Today’s CPA. Matt also regularly publishes articles on Forbes as a contributor, where he covers tax litigation, tax fraud and foreign reporting tax matters.  

Matt has also served as a tax law professor at the Southern Methodist University Dedman School of Law, where he taught Corporate Income Taxation.

Representative Experience
  • Represented clients in U.S. Tax Court, obtaining concessions of more than $1.4 million of proposed income tax and accuracy-related penalties from IRS Chief Counsel.
  • Counsel of record in more than 100 U.S. Tax Court cases.
  • Represented client in obtaining full $150,000 civil penalty relief for failure to file Form 5500-EZ. 
  • Defended high-profile client in sensitive IRS $700,000 late-payment penalty proposed assessment. Full concession of penalty by IRS.
  • Defended clients in trust tax shelter IRS SEP examination. IRS agreed on no referral to IRS-Criminal Investigation and no fraud penalties.
  • Represented clients in U.S. Tax Court, obtaining full concession from IRS Chief Counsel that $1.2 million of capital gains should not be realized and more than $300,000 concession on accuracy-related penalties.
  • Regularly defend clients against IRS proposed international information return penalties (e.g., Forms 8938, 5471, 5472, 3520, and 3520-A).
  • Represented client in obtaining more than $900,000 of innocent spouse relief under section 6015(f) of the Code.
  • Represented clients in U.S. Tax Court, resulting in more than $750,000 of income tax and penalties concessions from IRS Chief Counsel.
  • Represented multiple clients regarding IRS penalty assessments for failure to file Forms 3520 under section 6039F. Obtained full six-figure concessions from IRS.
  • Successfully defeated DOJ-Tax’s motion to dismiss for lack of jurisdiction and subsequent motion to dismiss on grounds of mootness in case of first impression in U.S. District Court for the Northern District of Texas.
  • Represented hundreds of clients in IRS compliance programs, including Voluntary Disclosure Program, Streamlined Filing Compliance Procedures, Delinquent International Information Return Submission Procedures, and Delinquent FBAR Submission Procedures.
  • Regularly defend clients regarding FBAR compliance and penalty matters.
  • Represented client in IRS employment tax examination. Successfully raised section 530 relief, resulting in no additional employment taxes or penalties post-examination.
  • Defended estate after IRS imposed more than $400,000 in penalties for late filing, late payment, and failure to pay estimated income taxes. Full concession of all penalties by IRS Appeals.
  • Counsel in significant issue of first impression in Fifth Circuit Court of Appeals regarding constitutionality of passport revocation statute.
  • Regularly defend clients regarding trust fund recovery penalties in IRS administrative process and in federal district courts.
  • Represented clients in sensitive IRS matters, including Malta Pension Plans, syndicated conservation easements, and employee retention credit claims.
  • Authored varied tax opinions, including opinions on substantial risks of forfeiture and executive compensation, theft and capital losses, and tax consequences of settlements and judgments.
  • Regularly defend clients in IRS collection matters, including offers in compromise, installment agreements, and IRS Collection Due Process (CDP) cases.
Thought Leadership / News
Honors
  • Named a Top Author - Tax in JD Supra's Reader's Choice Awards (2023)
Organizational Involvement
  • American Bar Association
    • Tax Section
  • State Bar Texas
    • Tax Section
  • Dallas Bar Association
    • Tax Section
  • State Bar of Mississippi
    • Tax Section
Education
  • LL.M. in Taxation, New York University
  • J.D., summa cum laude, The University of Mississippi School of Law
  • M.S., Taxation, The University of Mississippi
  • B.S., Accountancy, The University of Mississippi
Bar Admissions
  • Texas (2015)
  • Mississippi (2011)
Court Admissions
  • 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
When I Feel Most At Home
  • Grilling outside with family
  • International travel
  • Playing poker