Robin L. Greenhouse
Subscribe to Robin L. Greenhouse's PostsRobin L. Greenhouse represents businesses and individuals in resolving complex, large-dollar federal tax controversies. Robin is adept at using dispute resolution techniques, including fast track mediation, pre-filing agreements, Internal Revenue Service (IRS) appeals and post-appeals mediation, and has been the lead lawyer in significant litigation. Over her 30-year career as a government and private practice tax litigator, she has argued more than 100 cases in federal courts at every level. Read Robin Greenhouse's full bio.
Tax Court Hands Eaton a Complete Victory on the Cancellation of its Advance Pricing Agreements
By Robin L. Greenhouse on Jul 28, 2017
Posted In Court Procedure Matters, IRS Guidance, Transfer Pricing Resource, Uncategorized
On July 26, 2017, the United States Tax Court (Tax Court) handed a complete victory to Eaton Corporation (Eaton) relating to the Internal Revenue Service’s (IRS) cancellation of two Advance Pricing Agreements (APA). Eaton Corporation v. Commissioner, TC Memo 2017-147. The Tax Court held that the IRS had abused its discretion in cancelling the two successive...
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BEWARE: Whistleblowers Can “Out” You to the IRS!
By Kevin Spencer and Robin L. Greenhouse on Jul 24, 2017
Posted In IRS Guidance, Privilege and Non-Disclosure, Settlements, Uncategorized
Not only should companies worry about the Internal Revenue Service (IRS) auditing their returns, but they also have to be aware of a potential assault from within. Indeed, current and former employees have an incentive to air all of your tax issues with the hope of being rewarded for the information. Section 7623(b) was added...
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John Doe Intervenes in Virtual Currency Summons Enforcement Case
By Robin L. Greenhouse on Jul 21, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Uncategorized
The Internal Revenue Service (IRS) has broad authority under Internal Revenue Code (IRC) Section 7602 to issue administrative summonses to taxpayers and third parties to gather information to ascertain the correctness of any return. If the IRS does not know the identity of the parties whose records are covered by the summons, the IRS may...
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Appeals Large Case Pilot Program Draws Criticism
By Robin L. Greenhouse on Jun 15, 2017
Posted In IRS Appeals, IRS Audits, IRS Guidance, Uncategorized
In October 2016, the Internal Revenue Service (IRS) revised the Internal Revenue Manual (Manual) 8.6.1.4.4 to provide IRS Appeals Division (Appeals) with discretion to invite representatives from the IRS Examination Division (Exam) and IRS Office of Chief Counsel (Counsel) to the Appeals conference. Many tax practitioners opposed this change, believing that it undermines the independence...
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The IRS’s Assault on Section 199 (Computer Software) Doesn’t Compute
By Jean A. Pawlow, Kevin Spencer and Robin L. Greenhouse on Apr 24, 2017
Posted In Court Procedure Matters, IRS Appeals, IRS Audits, IRS Guidance, Trial Courts, Uncategorized
Internal Revenue Code Section 199 permits taxpayers to claim a 9 percent deduction related to the costs to develop software within the U.S. The relevant regulations and their interpretation, however, place substantial restrictions on claiming the benefit. Moreover, the regulations and the government’s position haven’t kept up with the technological advances in computer software. Before claiming...
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IRS is Required to Search Tax Return Information Records to Help Determine Worker Classification
By K. Christy Vouri-Misso, Robin L. Greenhouse and Ruth Wimer on Apr 7, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Tax Refunds, Uncategorized
On April 5, 2017, in an unanimous court reviewed opinion, the United States Tax Court determined that disclosure of a worker’s tax return information to absolve the employer from liabilities arising out of the employer’s withholding requirement is not subject to the general prohibition against disclosing taxpayer return information pursuant to Internal Revenue Code (IRC)...
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Acting IRS Chief Counsel appoints new Deputy Chief Counsel (Operations)
By Robin L. Greenhouse on Mar 30, 2017
Posted In Court Procedure Matters, IRS Appeals, IRS Audits, IRS Guidance, Uncategorized
The Acting Chief Counsel announced that effective April 1, 2017, Drita Tonuzi will serve as the Deputy Chief Counsel (Operations), in Washington DC. In this position, Ms. Tonuzi will provide legal guidance and litigation support to the Internal Revenue Service (IRS) and the Departments of Treasury and Justice in all matters pertaining to the administration...
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Understanding LB&I “Campaigns”
By Kevin Spencer and Robin L. Greenhouse on Mar 8, 2017
Posted In IRS Audits, IRS Guidance, Uncategorized
On March 3, 2017, KPMG and the Internal Revenue Service (IRS) held a joint webcast presentation regarding the Large Business & International’s (LB&I) new “Campaign” examination process. The IRS speakers for the presentation were Tina Meaux (Assistant Deputy Commissioner Compliance Integration) and Kathy Robbins, Director (Enterprise Activities Practice Area). On February 1, 2017, we blogged...
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Run for Cover—IRS Unveils Initial “Campaigns” for LB&I Audits
By Kevin Spencer, Robin L. Greenhouse, McDermott Will & Emery and McDermott Will & Emery on Feb 1, 2017
Posted In IRS Audits, IRS Guidance, Uncategorized
They’re here! On January 31, 2017, the Internal Revenue Service (IRS) Large Business & International (LB&I) division released its much-anticipated announcement related to the identification and selection of campaigns. The initial list identifies 13 compliance issues that LB&I is focused on and lists the specific practice area involved and the lead executive for each campaign. ...
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US Supreme Court Denies Petitions for Certiorari Filed In Two Federal Tax Cases
By Robin L. Greenhouse on Jan 13, 2017
Posted In Court Procedure Matters, Trial Courts, Uncategorized
On January 9, 2017, the US Supreme Court denied the petitions for certiorari filed in two federal tax cases. In Chemtech Royalty Assoc. LP v. United States, Sup. Ct. Dkt. No. 16-810 (2016), 823 F.3d 282 (5th Cir. 2016), Dow Chemical Co. challenged the decisions by the US Court of Appeals for the Fifth Circuit...
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