Fulbright & Jaworski L.L.P.
- Tax
- Federal Tax Controversies
- Federal Tax
- Attorney, Internal Revenue Service Office of Chief Counsel, Houston District Counsel Office, Houston, Texas, 1987 - 1997
- Special Trial Attorney, Internal Revenue Service Office of Chief Counsel, Midstates Regional Counsel Office, Dallas, Texas, 1997 - 1999
- Counsel/Senior Counsel, Fulbright & Jaworski L.L.P., Houston, Texas, 1999 - present
Richard spent the first twelve years of his career with the Internal Revenue Service Office of Chief Counsel – ten as an Attorney in the Houston District Counsel Office and two as a Special Trial Attorney in the Midstates Regional Counsel Office. He entered private practice in 1999, joining the Houston office of Fulbright & Jaworski L.L.P., and has been in private practice for twelve years.
Throughout his career, Richard has focused his practice on federal tax controversies. Due to the combination of his government and private practice experience, he has developed a unique understanding of both sides of tax controversies and an extensive knowledge of federal tax procedure.
Richard has handled a wide variety of federal tax cases, including matters pertaining to income tax, estate and gift tax, employment taxes, and excise taxes, involving corporations, partnerships, individuals, and exempt organizations. He has handled examination cases at various stages of the process, from the inception of an examination, through information document requests, summonses, settlement initiatives, administrative appeals, and litigation. He has handled hundreds of cases in United States Tax Court, taking a number of cases to trial, and has handled cases in the U.S. Court of Federal Claims and federal district court. He has also handled criminal investigations and collection matters.
Over the course of his career, Richard has represented clients in matters ranging in size from a few hundred dollars to several billion dollars, most being resolved prior to trial. He has also advised clients with potential federal tax compliance issues prior to the development of any controversies.
- Represented public transportation company before U.S. Tax Court regarding worthless stock loss deduction
- Represented chemical transportation and storage company before IRS Examination function and IRS Appeals Office regarding income, expense, withholding and penalty issues in connection with international transactions
- Represented partnership entity before IRS Appeals Office regarding tax treatment of complex financial derivative transaction
- Represented public refining company in connection with IRS summonses regarding international transaction, involving attorney-client, work product and tax practitioner privilege issues
- Represented twenty high net worth individuals, and associated partnership and trust entities, before IRS Examination function and IRS Appeals Office in connection with IRS settlement initiatives involving listed transactions
- Represented public manufacturing company before U.S. Tax Court regarding deductions in connection with corporate restructuring transaction
- Represented industrial laundry company before U.S. Tax Court regarding expense, depreciation and accounting method issues
- Represented labor union before U.S. Tax Court regarding unrelated business taxable income and statute of limitations issues
- Represented construction company before U.S. Court of Federal Claims regarding employment tax issues involving reimbursement of employee expenses
- Represented partnership before U.S. Tax Court regarding issues in connection with disposition of the assets of a gas-fired power plant, including associated power purchase agreements
- Represented IRS before U.S. Tax Court in multibillion dollar case involving deductions claimed for dismantlement, removal and restoration expenses with respect to oil and gas facilities at Prudhoe Bay, Alaska
- Represented IRS before U.S. Tax Court in case involving transfer pricing/cost sharing, accounting method, and research credit issues involving computer software
-
Houston Bar Association - Taxation Section
- Treasurer (2003 - 2004)
- Secretary (2004 - 2005)
- Chair-Elect (2005 - 2006)
- Chair (2006 - 2007)
- State Bar of Texas
- IRS Special Act Award (1991)
- IRS Performance Awards (1992 - 1994, 1997)
- Attorney of the Year in the IRS Southwest Region (1995)
- Assistant Commissioner for Criminal Investigation, Honorary Special Agent (1995)
- Chief Counsel National Team Litigation Award for his role as lead counsel in the trial of the Prudhoe Bay issue in the ExxonMobil case in U.S. Tax Court (1998)
- Co-author, "IRS Targets Employment Taxes To Close Tax Gap," Fulbright Briefing, October 9, 2009
-
"IRS Criminal Tax Symposiums," featured speaker:
- Fort Worth, Texas, December 1992
- Houston, Texas, March 1993
- Charlotte, North Carolina, June 1993
1987 - J.D., The University of Texas School of Law
1984 - B.B.A., with Highest Honors, International Business, The University of Texas at Austin
While attending law school, Richard was a member of the International Law Society.
Licensed to practice law in Texas; admitted to practice before U.S. Tax Court, U.S. Court of Federal Claims, U.S. District Court for the Southern District of Texas, U.S. Court of Appeals for the Fifth Circuit and U.S. Court of Appeals for the D.C. Circuit.
Richard is an active member of a fantasy baseball league, and is an avid fan of jazz and the blues.



