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Overview

Robert knows taxing authorities and government agency investigations inside and out. He spent six years as senior attorney with the IRS Office of Chief Counsel.

Robert deeply understands the world of federal and state taxes, and helps clients with state and local franchise, income, sales, use and property tax issues, as well as dealing with multistate voluntary disclosures for taxes owed. He interfaces with the Internal Review Service (IRS) to help nonprofit clients get needed exemption status. He also works with nonprofits on ongoing compliance issues associated with related party transactions and employee compensation.

In white collar matters, Robert specializes in helping healthcare and other professionals against allegations or investigations of white collar crimes in Securities and Exchange Commission (SEC), Department of Justice (DOJ) and Office of Inspector General investigations. Having been on the other side of the table, Robert understands how investigators think and act, and how they approach potential fraud and compliance issues. He has also defended companies against whistleblower assertions, specifically against the False Claims Act and allegations of Stark Law violations.

Robert also represents private investment funds during SEC and DOJ investigations into allegations of misvaluing assets and improper record keeping, and he has defended medical device manufacturers against breach of contract claims.


Industry

Services

Recognition

  • IRS Office of Chief Counsel Lucite Award, 2013
  • IRS Bronze Litigation Medallion

Education

  • J.D., University of Illinois College of Law
      • Order of the Coif
      • CALI Excellence for the Future Awards in Bankruptcy, Contracts, Criminal Procedure, and Property
  • B.A., Michigan State University

Admissions

  • Illinois
  • U.S. Court of Appeals, Seventh Circuit
  • U.S. Tax Court
  • Wisconsin
  • U.S. District Court, Northern District of Illinois
  • U.S. District Court, Northern District of Illinois (Trial Bar)

Professional Associations and Memberships

  • American Bar Association
  • American Health Lawyers Association
  • Federal Bar Association, Section on Taxation
  • State Bar of Wisconsin
Experience
  • Persuaded IRS to completely concede $780,000 in penalties and interest related to final tax return filing for a dissolved entity.
  • Represented client as co-counsel in eight-day trial before United States Tax Court concerning debt versus equity issues under Internal Revenue Code section 385 and write-offs of partially worthless bad debt totaling $92 million over nine tax years.
  • Advised client on tax implications of amended employment contract and how to make I.R.C. Section 83(b) election in relation to stock granted under new employment contract.
  • As co-counsel, obtained favorable results in federal tax audit, reducing total tax and penalties due and obtaining favorable adjustments not initially proposed by examiner in relation to real property disposition.
  • Represented clients before the Internal Revenue Service before both Examination and Appeals.
  • Obtained withdrawal of federal tax lien filed against client in relation to employment tax liabilities.
  • Defended multiple clients in Securities Exchange Commission investigations regarding accounting and investment practices.
  • Advised nonprofit clients on various state and local tax compliance issues, including applicability of state transfer and real property taxes, and effects of state tax compliance issues on local tax.
  • Assisted in negotiation of settlement with state and federal authorities related to allegations of False Claims Act violations wherein government damages claim of more than $100 million was settled for less than $5 million.
  • Assisted client in obtaining abatement of approximately $150,000 in late filing and penalties related to employment tax and in negotiating payment plan for remaining liabilities with IRS.
  • Led state and local tax due diligence for multiple green energy acquisitions.
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