Edward M. Robbins, Jr.

E-Mail Address: robbins@taxlitigator.com
Telephone: (310) 281-3247
Facsimile: (310) 859-5129

Practice: 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 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

Member:

    •     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

Education:

    •    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.”