- Tax
- Tax Litigation
- Tax Crimes
- Tax Controversies
- Tax Sharing Agreements and Related Disputes
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.
- 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
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American Bar Association - Section of Taxation
- Court Procedure and Practice Committee
- Administrative Practice Committee
- Pro Bono Committee
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State Bar of Texas Tax Section
- Vice Chair of Texas Tax Lawyer
- Houston Bar Association
- Houston Young Lawyers Association
- Co-author, "IRS Gives Taxpayers Third Bite At The Apple; Announces Third Offshore Voluntary Disclosure Program," Fulbright Briefing, January 11, 2012
- Co-author, "IRS's Latest Directive On Economic Substance Doctrine Provides Welcome News," Fulbright Briefing, July 22, 2011
- Co-author, "IRS Releases Final Schedule for Reporting Uncertain Tax Positions and Clarifies Policy of Restraint," Fulbright Briefing, September 28, 2010
- Co-author, "Recent IRS Administrative Guidance on Economic Substance Leaves Many Unanswered Questions," Fulbright Briefing, September 17, 2010
- Co-author, "Taxpayer Victory in 'Deloitte' Breathes Fresh Air Into Continuing Battle Over Tax Accrual Work Papers," BNA Daily Tax Report, August 3, 2010
- Co-author, "IRS Releases Draft Schedule and Instructions for Reporting Uncertain Tax Positions," Fulbright Briefing, April 23, 2010
- Co-author, "Clarification of the Economic Substance Doctrine May Have Beneficial Side Effects for Taxpayers," Fulbright Briefing, March 30, 2010
- Co-author, "IRS About To Start Detailed Employment Tax Examinations," Fulbright Briefing, February 2010
- Co-author, "IRS Announces New Broad Disclosure Requirements for Uncertain Tax Positions," Fulbright Briefing, January 2010
- Co-author, "Recent Taxpayer Economic Substance Victories Provide Blueprint for Success," BNA Daily Tax Report, December 10, 2009
- Co-author, "IRS Takes Aim at Offshore Services to the Oil & Gas Industry," Fulbright Briefing, November 2009
- Co-author, "IRS Targets Employment Taxes To Close Tax Gap," Fulbright Briefing, October 2009
- Co-author, "IRS Extends Deadline for Voluntary Disclosure Program Until October 15, 2009," Fulbright Briefing, September 2009
- Co-author, "Newly Minted 'For Use in Possible Litigation' Test of Textron May Have Far-Reaching Implications for Taxpayers," BNA Daily Tax Report, August 28, 2009
- Co-author, "U.S. Court of Appeals Rules That IRS is Entitled to Tax Accrual Work Papers," Fulbright Briefing, August 2009
- Co-author, "IRS Targets Compensation Deductions for Discounted and Backdated Stock Options," Fulbright Briefing, August 2009
- Co-author, "Where is the 'United States' for Federal Tax Purposes? ," The Texas Tax Lawyer, May 2009
- Co-author, "IRS Makes Limited Time Offer to Taxpayers With Undisclosed Offshore Accounts," Fulbright Briefing, April 2009
- Co-author, "Tax Issues for Investors in Alleged Ponzi Schemes," Fulbright Briefing, March 2009
- Co-author, "Foreign Bank and Financial Accounts Must be Reported by June 30, 2009," Fulbright Briefing, May 2009
- Co-author, "IRS Focusing on Taxpayers with Undeclared Foreign Accounts," Fulbright Briefing, July 2008
Rob is a regular speaker at programs sponsored by the Tax Executives Institute and accounting firms.
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.
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.



