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Robert Probasco

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Quoted In Reuters On Irs Relying On Economic Substance Doctrine, Robert D. Probasco Aug 2013

Quoted In Reuters On Irs Relying On Economic Substance Doctrine, Robert D. Probasco

Robert Probasco

No abstract provided.

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Ethics And Expected Changes To Circular 230, Fred Murray, Richard Goldstein, Matthew Lucey, Jack Manhire, Robert D. Probasco May 2013

Ethics And Expected Changes To Circular 230, Fred Murray, Richard Goldstein, Matthew Lucey, Jack Manhire, Robert D. Probasco

Robert Probasco

No abstract provided.

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Quoted In Tax Notes Today On Valuation Misstatement Case, Robert D. Probasco Mar 2013

Quoted In Tax Notes Today On Valuation Misstatement Case, Robert D. Probasco

Robert Probasco

No abstract provided.

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Quoted In Tax Notes Today On Gross Valuation Misstatement Penalty, Robert D. Probasco Mar 2013

Quoted In Tax Notes Today On Gross Valuation Misstatement Penalty, Robert D. Probasco

Robert Probasco

No abstract provided.

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Transferee Liability, Robert D. Probasco Mar 2013

Transferee Liability, Robert D. Probasco

Robert Probasco

No abstract provided.

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Circular 230 And Rules Of Professional Conduct In Giving Tax Advice, Robert D. Probasco Jan 2013

Circular 230 And Rules Of Professional Conduct In Giving Tax Advice, Robert D. Probasco

Robert Probasco

No abstract provided.

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Transferee Liability, George Hani, Tamara Ashford, Robert D. Probasco Aug 2012

Transferee Liability, George Hani, Tamara Ashford, Robert D. Probasco

Robert Probasco

No abstract provided.

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Quoted In Daily Tax Report On Starnes Ruling, Robert D. Probasco Jun 2012

Quoted In Daily Tax Report On Starnes Ruling, Robert D. Probasco

Robert Probasco

No abstract provided.

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Quoted In Law360 On Ex-Ceo Pay, Robert D. Probasco Mar 2012

Quoted In Law360 On Ex-Ceo Pay, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Proposed Amendments To The Rules Of The United States Tax Court, Robert D. Probasco Feb 2012

Comments On Proposed Amendments To The Rules Of The United States Tax Court, Robert D. Probasco

Robert Probasco

We commend the Court for the time and thought that has been put into preparing the proposed amendments to its rules of practice and procedure. We also appreciate the opportunity to comment on the proposal and hope that our comments prove to be helpful. We agree with the proposed rules for the most part and believe that they represent an improvement for taxpayers, practitioners , and the Court . We respectfully suggest, however, the Court consider certain changes that we believe could further improve the procedures.

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The New Application Of Transferee Liability, Robert D. Probasco Dec 2011

The New Application Of Transferee Liability, Robert D. Probasco

Robert Probasco

No abstract provided.

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Tefra Audits And Refund Claims, Robert D. Probasco Oct 2011

Tefra Audits And Refund Claims, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Procedures Regarding Ex Parte Communications With Appeals, Robert D. Probasco, Joel N. Crouch, Stephanie D. Mongiello Aug 2011

Comments On Procedures Regarding Ex Parte Communications With Appeals, Robert D. Probasco, Joel N. Crouch, Stephanie D. Mongiello

Robert Probasco

Section 1001 (a) of the Internal Revenue Service Restructuring and Reform Act of 1998 (the "1998 Act") required the Commissioner to develop a p lan to ensure the independence of Appeals , including prohibiting ex parte communications between Appeals and other IRS employees to the extent that such communications appear to compromise the independence of Appeals. In our experience, many taxpayers question the independence of an Appeals function that is still part of the IRS. We share the IRS' support for an effective Appeals process, which requires not only that Appeals is independent but also that taxpayers perceive Appeals to …

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Quoted In The Fort Worth Business Press On Fraudulent Tax Returns Surge, Robert D. Probasco Apr 2011

Quoted In The Fort Worth Business Press On Fraudulent Tax Returns Surge, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Proposed Amendments To The Rules Of The United States Tax Court (Aba), Robert D. Probasco Mar 2011

Comments On Proposed Amendments To The Rules Of The United States Tax Court (Aba), Robert D. Probasco

Robert Probasco

On behalf of the Section of Taxation (“Section”) of the American Bar Association, the following comments are provided in response to the invitation for public comments issued by the United States Tax Court (the “Court”) with respect to proposed amendments to the Court’s Rules of Practice and Procedure announced on December 20, 2010.1 The proposed amendments include amendments concerning timing for filing summary judgment motions, Rule 1552 computations, motions regarding elections to proceed under the small tax case procedure, answers in lien and levy cases, and recognition of mediation as a form of alternative dispute resolution. These comments have not …

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What Tax Lawyers Need To Know Before Choosing A Forum For Their Next Federal Civil Tax Litigation Dispute, Robert D. Probasco Oct 2010

What Tax Lawyers Need To Know Before Choosing A Forum For Their Next Federal Civil Tax Litigation Dispute, Robert D. Probasco

Robert Probasco

No abstract provided.

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Quoted In Bna Daily Tax Report On Uncertain Tax Positions Guidance, Robert D. Probasco Oct 2010

Quoted In Bna Daily Tax Report On Uncertain Tax Positions Guidance, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Proposed Amendments To Treasury Circular 230, Robert D. Probasco, David Colmenero, Mandi L. Matlock Oct 2010

Comments On Proposed Amendments To Treasury Circular 230, Robert D. Probasco, David Colmenero, Mandi L. Matlock

Robert Probasco

The vast majority of federal individual income tax return s are prepared by paid tax return preparers or by taxpayers using consumer tax preparation software. Circular 230 governs practice before the Service by attorneys, certified public accountants, enrolled agents, enrolled actuaries, and enrolled retirement plan agents (collectively, "practitioners" ). Circular 230, however, has not applied to paid tax return preparers who did not fall within any of the categories of practitioners. Various observers, including the National Taxpayer Advocate and consumer advocacy groups, have expressed significant concerns about the lack of regulation of such unenrolled tax return preparers. 1n June 2009, …

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Federal Tax Update, Robert D. Probasco Jun 2010

Federal Tax Update, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Proposal Regarding Uncertain Tax Positions, Robert D. Probasco, Bruce Bernstien, Mark Horowitz May 2010

Comments On Proposal Regarding Uncertain Tax Positions, Robert D. Probasco, Bruce Bernstien, Mark Horowitz

Robert Probasco

These comments are presented on behalf of the Section of Taxation of the State Bar of Texas. The principal drafters of these comments were Robert D. Probasco, Mark Horowitz and Bruce Bemstien. Additional contributors were Val J. Albright, David E. Colmenero, Joel N. Crouch, Brian Dethrow, Kenneth M. Horwitz and Ronald D. Kerridge. The Committee on Government Submissions (COGS) of the Section of Taxation of the State Bar of Texas has approved these comments. Daniel G. Baucum is the Chair of COGS, and Emily Parker and Daniel J. Micciche reviewed the comments on behalf of COGS.

The following comments are …

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Living With Transparency, Robert D. Probasco Nov 2008

Living With Transparency, Robert D. Probasco

Robert Probasco

No abstract provided.

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Retention Requirements For Tax Records, Robert D. Probasco Jan 2008

Retention Requirements For Tax Records, Robert D. Probasco

Robert Probasco

No abstract provided.

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Ethics And Standards Of Tax Practice In The New Age Of Transparency: From Self-Assessment To Self-Audit, Emily A. Parker, Robert D. Probasco Mar 2007

Ethics And Standards Of Tax Practice In The New Age Of Transparency: From Self-Assessment To Self-Audit, Emily A. Parker, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Proposed Regulations On Reportable Transactions, Robert D. Probasco, M. Todd Welty, Brandy N. Williams, Stephen A. Beck Jan 2007

Comments On Proposed Regulations On Reportable Transactions, Robert D. Probasco, M. Todd Welty, Brandy N. Williams, Stephen A. Beck

Robert Probasco

These comments are presented on behalf of the Section of Taxation of the State Bar of Texas. The principal drafters of these comments were M. Todd Welty, Robert D Probasco. Brandy N .. Williams, and Stephen A.. Beck.. The Committee on Government Submissions ("COGS") of the Section of Taxation of the State Bar of Texas has approved these comments. Patrick O'Daniel is the Chair of COGS and the other members of COGS include Paul Asofky, Stanley Blend, Vester Hughes, Emily Parker and Steve Salch.

Although many of the people who participated in preparing, reviewing and approving these comments have clients …

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Irs Audits And Appeals, Emily A. Parker, Robert D. Probasco Mar 2006

Irs Audits And Appeals, Emily A. Parker, Robert D. Probasco

Robert Probasco

No abstract provided.

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Irs Audits And Appeals, Robert D. Probasco Mar 2006

Irs Audits And Appeals, Robert D. Probasco

Robert Probasco

No abstract provided.

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Taxation Of Attorney Fees - Recent Developments, Robert D. Probasco, Marc Grossberg Feb 2005

Taxation Of Attorney Fees - Recent Developments, Robert D. Probasco, Marc Grossberg

Robert Probasco

No abstract provided.

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The Deliberative Process Privilege, Robert D. Probasco, John Galotto, Michael Kearns, Richard Goldman Sep 2004

The Deliberative Process Privilege, Robert D. Probasco, John Galotto, Michael Kearns, Richard Goldman

Robert Probasco

No abstract provided.

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