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Internal Revenue Service: Practice and Procedure Deskbook (5th Edition)

Author(s): Erin M. Collins, Edward M. Robbins, Jr.
Practice Area: Income tax, Tax
Date: Oct 2017 i Other versions can be found in the Related Items tab.
ISBN: 9781402429859
PLI Item #: 224505

“Navigating the complex maze of IRS practice and procedure rules can be daunting — but the task is made much easier with help from two of the most experienced tax controversy attorneys in the business today.”
– Kendall Jones, Sutherland

Internal Revenue Service: Practice and Procedure Deskbook provides the thorough legal, procedural, and strategic information attorneys, accountants and other tax professionals need to represent clients more effectively when dealing with the IRS, including guidance on:

  • Examinations — including how to deal with IRS document requests, narrow the scope of IRS audits, and reach settlements as part of a correspondence, office or field examination
  • Large Business & International Division Examinations — from how to prepare for LB&I examinations to how to use IRS programs to expedite resolutions
  • Assessments — with clear coverage of IRS assessment procedures and the Code’s complex mitigation provisions
  • Civil Penalties — including steps you can take to abate penalties and minimize the risk of particular penalties being asserted, as well as, a chart containing a detailed summary of the numerous civil penalties listed by Code section
  • Tax Fraud — with details on how to make voluntary disclosures to avoid investigations, assemble defense teams, and deploy “good faith” and other defenses
  • Appeals — including how to proceed effectively in appeals conferences, as opposed to examinations, and pick the right settlement options for each client
  • Litigation — with guidance on how to select the most favorable judicial forum for each case and cope with the Tax Court’s unique rules of practice and procedure
  • Collections — from Collection Due Process hearings to surefire solutions to clients’ collection problems
Internal Revenue Service Practice and Procedure Deskbook offers analysis of key Tax Court decisions and other case law, and highlighted “Practice Pointers” and other tips for successfully representing clients in IRS dealings.
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Erin M. Collins is the retired Managing Director of a multi-national accounting firm’s Tax Controversy Services practice for the Western Area. Previously, Erin was a Special Trial Attorney with IRS Western Regional Counsel. She was responsible for the development and litigation of high profile, and complex tax cases. In 1995, and again in 1997, she received Chief Counsel’s highest award, the National Litigation Award, and in 1993 received the Western Region’s highest Litigation Award for her outstanding achievements. She has represented clients in federal examinations and IRS appeals on domestic and international tax issues. Erin has wide-ranging experience with alternative dispute resolution procedures in resolving difficult or uncertain federal tax issues. Erin has represented a number of clients before the U.S. Tax Court and has represented the government in several significant and complex tax cases.


Representation includes Federal and California civil tax and criminal tax litigation together with civil tax and criminal tax controversy matters before the Internal Revenue Service, the California Franchise Tax Board, the California State Board of Equalization, California Employment Development Department and various state taxing authorities of individuals, business enterprises, partnerships, limited liability companies, and corporations. Representation also includes individuals and organizations involved as targets, subjects, or witnesses in Federal and California criminal investigations and related grand jury and pre-trial proceedings, trials and appeals.

Awards and Honors

  • IRS Criminal Investigations Outstanding National Criminal Tax Prosecutor, 2004
  • U.S Department of Justice, Employee Volunteer Service Award, 2002
  • IRS Criminal Investigations Award, 2002
  • Law Enforcement Award, Internal Revenue Service, Criminal Investigation, Los Angeles Field Office, 2001
  • Trial Instructor, Attorney General's Advocacy Institute, 1988-2004
  • U.S. Department of Justice, Special Commendation Award, 1990
  • U.S. Department of Justice, Special Commendation Award, 1986
  • IRS Chief Counsel Special Achievement Award, 1982
  • Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization

Professional Background

  • Assistant United States Attorney, Central District of California, Tax Division, Office of the United States Attorney
    • Chief of Tax Division, 1994-2004
    • Assistant Division Chief, 1988-1994
    • Assistant United States Attorney 1983-2004

As Chief of the Tax Division, Central District of California's United States Attorney's Office, Edward M. Robbins, Jr., handled a full caseload specializing in complex civil and criminal tax litigation. In addition to his litigation duties he was responsible for the management and coordination of the Tax Division's tax 3/29/2013 cases and supervised the Special AUSA's in bankruptcy matters and worked with the Assistant Attorney General (Tax) to develop and ensure uniform national tax policy.

Mr. Robbins represented the government in a variety of federal criminal tax prosecutions and civil tax actions and proceedings before the United States District Court, the United States Bankruptcy Court, the United States Bankruptcy Appellate Panel and the state courts. He handled numerous civil and criminal tax cases and matters, including:

  • grand jury investigations and criminal prosecutions for tax crimes and related white collar and drug crimes
  • lawsuits for refund of income, employment, excise, estate and gift taxes, to collect delinquent tax liabilities and to foreclose federal tax liens (including fraudulent conveyance actions)
  • actions affecting property in which the United States claims a tax lien (including actions in interpleader, eminent domain and for partition), probate proceedings
  • adversary proceedings and contested matters in bankruptcy (including objections to tax claims, objections to confirmation of Chapter 11 and 13 reorganization plans and complaints to determine dischargeability of debt and for turnover of property)
  • actions to enforce IRS administrative summonses
  • lawsuits for summary review of jeopardy and termination assessments
  • lawsuits to recover wrongfully levied property
  • lawsuits for damages for failure to release levy and wrongful collection activity
  • lawsuits against IRS employees for constitutional torts
  • Title 7 and FTCA actions involving the IRS

Mr. Robbins has represented the government at the trial level in hundreds of significant and complex civil and criminal tax cases, including United States v. Galletti, ___U.S.___ (2004) (assessment against partnership valid against unassessed general partner); United States v. Brockamp, 519 U.S. 347 (1997) (no equitable tolling of tax refund claim statute of limitations); United States v. Williams, 514 U.S. 527 (1995)(defining "taxpayer"); United States v. Carlton, 512 U.S. 26 (1994)(retroactive tax statute valid); Church of Scientology of California v. United States, 506 U.S. 9 (1992)(summons enforcement jurisdiction); United States v. Schulman, 817 F.2d 1355 (9th Cir. 1987) (criminal tax fraud).

  • Loyola Law School, Adjunct Faculty, 2000-present
  • Federal Civil Tax Procedure
  • Federal Criminal Tax and Criminal Tax Procedure
  • Golden Gate University School of Law, Adjunct Faculty, 1996-2000
  • Federal Civil Tax Procedure
  • Senior Trial Attorney, Internal Revenue Service, 1978-1983


  • American College of Tax Counsel, 2012
  • UCLA Extension Annual Tax Controversy Institute
  • Advisory Board Member and Panelist, 1998 - present
  • Association of Tax Counsel
  • The State Bar of California, Taxation Section.
  • Beverly Hills Bar Association, Taxation Section.
  • Los Angeles County Bar Association, Taxation Section.
  • American Bar Association, Taxation Section.
  • Delegate to the California State Bar Conference
  • The State Bar of Hawaii
  • Washington D.C. Bar


  • LL.M., University of San Diego, Magna Cum Laude, 1984
  • J.D., Golden Gate University, with honors, 1978
  • B.S.E.E., Ohio State University, with honors, 1971

Bar Admittance:

  • U.S. Court of Appeals, Eighth Circuit, Ninth Circuit, D.C. Circuit
  • U.S. District Court, Central, Eastern, Northern and Southern Districts of California, District of Hawaii
  • U.S. Claims Court
  • U.S. Tax Court
  • State Bar of California
  • State Bar of Hawaii, District of Columbia Bar

Mr. Robbins is a frequent speaker on civil and criminal tax practice, procedure, controversy and litigation matters, appearing before government agencies and professional organizations, including the American Bar Association, the State Bar of California, UCLA Annual Tax Controversy Institute, Los Angeles County Bar and the Tax Executives Institute. Mr. Robbins is frequently quoted in the National Press on tax issues: Google "Edward Robbins Tax."