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Our Firm Edward M. Robbins, Jr.

EdR@taxlitigator.com Phone: (310) 281-3247
Fax: (310) 859-5129 Download Vcard

Edward M. Robbins, Jr. has considerable experience handling sensitive issue civil examinations and administrative appeals, civil trials and appeals defending complex criminal tax investigations, civil trials and appeals, and defending criminal tax prosecutions (jury and non-jury).  He has successfully handled literally hundreds of matters involving previously undeclared interests in foreign financial accounts and assets.

Representation  currently includes Federal and California civil tax and criminal tax litigation together with civil tax and criminal tax controversy  administrative 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.  In the world of civil tax and criminal tax investigations, Mr. Robbins has truly touched every conceivable issue during his lengthy and successful career.

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 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

Presentations:

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.”

  • Speaker, Strafford, October, 2023, Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process
  • Speaker, Strafford, September, 2023, Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process
  • Speaker, CalCPA, July, 2023, Form 8300 Reporting, Cash Intensive Business Audits
  • Speaker, Strafford, June, 2023, Foreign Information Return Penalties After Farhy: Case Review and Updates, Penalty Abatements, Refund Claims
  • Speaker, Beverly Hills Bar Association, May, 2023, IRS International Penalties After Farhy
  • Speaker, ABA 39th Annual National Institute on Criminal Tax Fraud, December, 2022, Criminal Tax Workshop
  • Speaker, 56th Annual Hawaii Tax Institute, November, 2022, FBAR Reporting, Trends, Pitfalls, and Enforcement. What You Need to Discuss With Your Clients
  • Speaker, Spidell, October, 2022, Form 8300 Reporting/Cash Intensive Business Audits
  • Speaker, Lorman Educational Services, June, 2022, Currency Transaction Report: How to File and Common Errors
  • Speaker, 37th National Institute on Criminal Tax Fraud, December 2020, Criminal Tax Workshop
  • Speaker, 36th National Institute on Criminal Tax Fraud, December 2019, Voluntary Disclosures and Addressing the Sins of the Past: Ethical and Other Considerations
  • Speaker, 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, December 2018, Wisdom Across the Generations: How to Address Ethical Challenges in Tax Practice
  • Panelist, “When the Past Isn’t the Past: How to Correct Past Wrongdoing,” University of Southern California, 2016 USC Tax Law Institute
  • Speaker, “Mock Trial Character Witness,” ABA Tax Section, 33rd Annual National Institute on Criminal Tax Fraud
  • Panelist, “Criminal Tax 101 – or How to Keep Your Clients and You Out of Jail,” California State University, Los Angeles
  • Speaker, “Hot Topics in IRS Enforcement – Tips From the Tax Trenches!,” KPMG Continuing Professional Education
  • Speaker, “Tax Risk Management in the U.S.” (Session 5: Reducing Tax Risks),” UCLA Extension
  • Speaker, “Hot Topics in IRS Enforcement – Tips From the Tax Trenches!,” California CPA Education Foundation
  • Panelist, “To File or Not to File –That is the Question,” ABA Tax Section, 2016 Mid-year Meeting
  • Panelist, “Tax Practitioner Penalties, New I.R.C. §6694 and Beyond!,” University of Southern California, 2016 USC Tax Law Institute
  • Panelist, “Foreign Financial Assets: You Can Run, but You Cannot Hide,” USC Gould School of Law, 2015 Tax Institute
  • Panelist, “Criminal Tax Enforcement,” California State University, Los Angeles, Extended Education
  • Panelist, “Ask the Experts:  Top Criminal Tax Practice Tips and Representation Strategies,” ABA Tax Section, 32nd Annual National Institute on Criminal Tax Fraud
  • Speaker, “Updates for IRS Enforcement ,” KPMG Korean NTS Seminar”
  • Panelist, “International Tax Audit & Appeals Including Statute of Limitations in the International Context,” International Tax, Tax Procedure & Litigation Committee, 2015 Annual Meeting of the California Tax Bar & California Tax Policy Conference
  • Panelist, “Advanced Tax Court Litigation,” International Tax, Tax Procedure & Litigation Committee, 2015 Annual Meeting of the California Tax Bar & California Tax Policy Conference

 Awards and Honors:

  • Selected to Southern California Super Lawyers, 2005 – 2006, 2009 – 2018
  • Elected as a Fellow of the American College of Tax Counsel, 2012
  • IRS Criminal Investigations Outstanding National Criminal Tax Prosecutor, 2004
  • 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
  • S. Department of Justice, Special Commendation Award, 1990
  • 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

Publications:

Mr. Robbins has extensively published and co-authored articles to include:

  • Farhy Reminds the IRS to Turn Square Corners, Not Cut Corners (Journal of Tax Practice and Procedure, Summer, 2023)
  • Tax Crimes, BNA Tax Management Portfolio, No. 636-3rd.
  • Erin M. Collins & Edward M. Robbins, Jr., Internal Revenue Service Practice and Procedure Deskbook, (Practicing Law Institute, 5th ed. 2017).
  • Tax Fraud, Chapter 37 Litigation Services Handbook: The Role of the Financial Expert, Fourth Edition.
  • How to Expose a Lying Witness: The Five Different Directions Technique of Cross Examination, (Mar. 28, 2017).
  • What You Need to Know About the Refund Statute of Limitations, Bloomberg BNA Daily Tax Report (July 3, 2014).
  • The Fifth Amendment FBAR Lives! (June 24, 2013) BNA Tax Notes.
  • What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account?, Journal of Tax Practice and Procedure, Oct.–Nov. 2012.
  • Counseling Corporations Involved in Government Investigations and the Principles of Federal Prosecution of Business Organizations, Corporate Business Taxation Monthly, Feb. 2009.
  • Edward Robbins, Jr., and Steven Toscher, The Options Aren’t Looking as Good, Journal of Tax Practice & Procedure, Oct. 2006.
  • The Effects of a Federal Tax Adjustment by the Internal Revenue Service on a California Personal Resident, California Tax Lawyer, Spring 2006.
  • Structuring Transactions and Currency Violations: The “Tax Crime” of the Future, CCH Tax Practice and Procedure, March 2005.
  • Strategic Options for Taxpayers—Federal Tax Procedure 101, Journal of Tax Practice & Procedure, January 2005.

Special Investigations:

As Special Master appointed by the Los Angeles  Superior Court, Mr. Robbins investigated the events surrounding the Los Angeles Department of Water and Power’s lawsuit in Jones v. City of Los Angeles.  As a result, in 2021 Mr. Robbins filed with the Court Clerk a  public 556 page report entitled Report on The Investigation into Any Violations Surrounding the Case and Action of Jones v. City of Los Angeles and Related Cases filed with the Los Angeles Superior Court in 2021.

Member:

  • American College of Tax Counsel, 2012 – present
  • 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
  • Federal Bar Association Member, Los Angeles Chapter

Bar Admittance:

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

Education:

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