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Internal Revenue Service Practice and Procedure Deskbook (Sixth Edition)

Author(s): Edward M. Robbins, Jr., Thomas Greenaway
Practice Area: Accounting and financial reporting, Estates and trusts, Litigation, Tax
Date: Sep 2020 i Other versions can be found in the Related Items tab.
ISBN: 9781402435911
PLI Item #: 293660

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
  • Claims for Refund and Refund Suits — including the effect of the COVID-19 pandemic on refunds and refund suits
  • 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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Edward M. Robbins, Jr. is a principal of Hochman, Salkin, Rettig, Toscher & Perez, P.C., specializing in civil and criminal tax litigation. He maintains an active practice before the U.S. Tax Court, the Federal District Courts in California, Hawaii, Washington D.C. and various Federal Circuit Courts of Appeals and the California State Courts. He frequently appears before the IRS, the California Franchise Tax Board and the California State Board of Equalization. Mr. Robbins is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization. Mr. Robbins’ tax practice includes a wide array of substantive areas, including income taxes, estate taxes, employment taxes, excise taxes, and sales taxes. He has received an “A-V” rating from Martindale-Hubbell. In addition to his civil tax practice, Mr. Robbins has an active practice in the criminal tax field, representing clients in the Federal and State courts, grand jury proceedings and before the IRS Criminal Investigation Division  and Department of Justice Tax Division. Prior to 2004, for eleven years as Chief of the Tax Division of the United States Attorney’s Office for the Central District of California, Mr. Robbins, in addition to his individual litigation duties, was responsible for the management and coordination of the Tax Division’s civil and criminal tax cases and supervised the Special AUSA’s in bankruptcy matters and worked with the Assistant Attorney General (Tax) and her staff to develop and ensure uniform national tax policy. Mr. Robbins was a trial attorney with the IRS office of Chief Counsel from 1978 to 1983, and from 1983 to 1993 he was an Assistant United States Attorney with the Tax Division.

Tom Greenaway leads KPMG’s Tax Controversy Services practice in New England. The practice works on behalf of clients with IRS revenue agents, revenue officers, specialists, IRS counsel attorneys, managers, Appeals Officers, and other revenue agents throughout New England, across the country, and around the world.

Tom focuses on representing clients before the IRS, from rulings and voluntary disclosures through examination, Appeals, and post-Appeals dispute resolution, with an emphasis on international tax matters. Tom also assists firm clients on general tax consulting matters.

Before joining KPMG, Tom practiced as a senior attorney in the Large & Midsize Business division of the IRS Office of Chief Counsel in Boston. While with the IRS Office of Chief Counsel, he served as U.S. Counsel to the Joint International Tax Shelter Information Centre. 

Tom is an active member of his community. Tom serves as a Council Director of the American Bar Association (ABA) Tax Section. Tom served two terms as a member and Chair of the Wayland Finance Committee. Tom was also elected to two terms on the Board of Finance in Chester, Connecticut. He is a member of the Boston Tax Forum and past chair of the Boston Bar Association Tax Section.

Tom is a frequent author on tax topics and has contributed articles to, among other publications, Tax Executive, Tax Notes, Tax Lawyer, and Taxes. He speaks regularly before professional organizations such as Tax Executives Institute and the ABA Tax Section. He has been a member of the faculty for the American Law Institute’s annual Tax Controversy Conference in 2017.

Tom earned a BA degree, cum laude, from Columbia College, and a JD degree, with honors, from the University of Connecticut School of Law.