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Robert Morris, Bob Morris, Morris, Fulbright & Jaworski L.L.P., Fulbright & Jaworski, Fulbright and Jaworski, Fulbright, tax litigation, tax, litigation, tax controversy, general taxation, taxation, certified public accountant, accountant, LLM, L.L.M., Houston
Robert C. Morris - Fulbright & Jaworski LLP
Robert C. Morris
Sr. Associate
D: +1 713 651 8404
Houston
Fulbright Tower
1301 McKinney
Suite 5100
Houston, TX 77010-3095
T: +1 713 651 5151
F: +1 713 651 5246
AREAS OF CONCENTRATION
EXPERIENCE

Rob Morris focuses his practice on tax matters, with an emphasis on tax controversies. Rob represents taxpayers in all phases of tax controversies, from preparing for and handling IRS audits, to preparing protests and negotiating with the IRS Appeals Office, to litigating tax controversies when necessary. Rob also has assisted clients in utilizing the IRS Fast Track Settlement process and other alternative dispute resolution alternatives.

In addition to advising clients on substantive tax matters, Rob also provides practical and cost effective counsel to clients on day-to-day issues that often arise during an IRS examination or in litigation. These include matters of privilege, responding to IRS information document requests, and intervening in or defending summons enforcement proceedings. Rob also has advised clients concerning tax collection matters, and making voluntary disclosures to the IRS. Rob is a certified public accountant, and worked in the tax department of a "Big Four" accounting firm prior to joining Fulbright. 

REPRESENTATIVE EXPERIENCE
  • Corporate taxpayer in U.S. district court refund action involving complex financial products, international tax issues, economic substance, substance over form and the step transaction doctrine
  • Corporate taxpayer in Tax Court action involving IRS's proposed disallowance of deduction for worthless stock of wholly-owned subsidiary
  • Corporate taxpayer in dispute involving withholding tax issues
  • Corporate taxpayer under IRS examination for civil tax fraud as a result of tax whistleblower's allegations
  • Corporate taxpayer in dispute regarding a Tax Sharing Agreement
  • Corporate taxpayer under IRS examination with respect to tax and penalty issues in connection with alleged Foreign Corrupt Practice Act violations
  • Corporate taxpayer in dispute involving the credit for research activities
  • Corporate taxpayers in responding to IRS administrative summons and subsequent judicial summons enforcement proceedings
  • Corporate taxpayer in dispute involving the Section 199 deduction for domestic production activities
  • Corporate taxpayer in dispute involving whether an advance was properly classified as debt or equity
  • Individual taxpayer who participated in "listed transactions" involving derivative financial instruments and foreign currency transactions on tax, penalty, and interest suspension issues
  • Individual taxpayer in dispute involving alleged "Mid Co" transaction and related transferee liability issues
  • Individual taxpayer under IRS examination for gift tax issues
  • Individual taxpayers in making voluntary disclosures of unfiled tax returns and undisclosed offshore assets to the IRS 
  • Tax-exempt organization in U.S. district court declaratory judgment action
PROFESSIONAL ACTIVITIES and MEMBERSHIPS
  • American Bar Association - Section of Taxation
    • Court Procedure and Practice Committee
    • Administrative Practice Committee
    • Pro Bono Committee
  • State Bar of Texas Tax Section
    • Vice Chair of Texas Tax Lawyer
  • Houston Bar Association
  • Houston Young Lawyers Association
PUBLICATIONS
SPEECHES

Rob is a regular speaker at programs sponsored by the Tax Executives Institute and accounting firms.

EDUCATIONAL BACKGROUND

2006 - LL.M., Taxation, with distinction, Georgetown University Law Center
2004 - J.D., cum laude, Brigham Young University
2004 - Masters, Accounting, Brigham Young University
2002 - B.S., Accounting, Brigham Young University

Rob was admitted to practice law in Texas in 2004. Rob is also admitted to practice before the United States District Court for the Southern District of Texas, the United States Tax Court, and the United States Court of Federal Claims. While in law school, Rob served on the Moot Court Team Board of Advocates and as a law clerk to a Utah District Court Judge. 

INTERESTS

Rob is married and has two young children. During his spare time, he enjoys spending time with his family and swimming. In college, Rob earned all-conference swimming honors and was an Academic All-American Honorable Mention.







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