Tax Litigation and Controversy, Criminal Tax Investigations, and Tax Collection (Internal Revenue Service and Tennessee Department of Revenue);
Taxation in Bankruptcies, Insolvencies, and Workouts; Business Workouts, Bankruptcy and Related Litigation.
From 1974 to 1980, Bob Pope was a trial attorney in the Office of Chief Counsel, Internal Revenue Service.
Mr. Pope focuses on tax procedures and processes of both the Internal Revenue Service and the Tennessee Department of Revenue, with an emphasis on litigation. He works closely with certified public accountants, tax lawyers, and enrolled agents to define procedures and processes not routinely used by those professionals. Mr. Pope defines realistic legal and practical solutions, including the choices and timing of workouts and bankruptcy, for businesses facing financial problems.
Mr. Pope is listed in The Best Lawyers in America (Taxation and Bankruptcy and Creditor/Debtor Rights Law). He is a Fellow in the American College of Tax Counsel. (www. actconline.org.)
•Planning Committee 2007 to Present: “Tennessee Federal Tax Conference,” an annual three-day conference held in November sponsored by the Tennessee Scoiety of Ceritfied Public Accountants and the Tennessee Federal Tax Institute.
•Trustee of The Tennessee Federal Tax Institute. President 2005 and 2006.
•Served as a director of the Mid-South Commercial Law Institute, and as its treasurer.
•Southeast Region Bar IRS Liaison Committee since 2002.
•Fellow of the American College of Tax Counsel.
SECTION ON TAXATION
American Bar Association
Mr. Pope was a founding member and the Chair of the Bankruptcy and Workouts Committee of the American Bar Association’s Section on Taxation.
Bankruptcy Task Force:
•Worked with Paul Asofsky, meetings with congressional staff members on tax provisions of proposed bankruptcy legislation and drafting of some tax provisions and review of all tax provisions of 2005 Bankruptcy Act (May, 1997 – Bankruptcy Task Force Report).
•Presentation of suggested tax changes to Tax Subcommittee of Bankruptcy Review Commission.
•Monitor congressional consideration of bankruptcy legislation and respond to congressional inquiries on tax provisions.
When passage of the new bankruptcy legislation was complete, the Bankruptcy Task Force came to its end. Working with Council members, notably Karen Hawkins, the Task Force was “converted” to a Standing Committee.
Bankruptcy and Workouts Committee:
2006-2010Regular Participant – Panelist/Speaker
June 2015Chair Elect
•On passage of the bankruptcy legislation, the Committee made several presentations to assure widespread delivery of the tax changes.
•Committee members address bankruptcy/tax issues at the request of the Section of Taxation, and various committees.
Member, COGS: 2009 - To Date
“S” Corporation Federal Tax Status – Property of the Bankruptcy Estate?, Norton’s Bankruptcy Law Adviser (July, 2013)
Collection Due Process Hearings – The Internal Revenue Manual: A Statement of Administrative Procedures?, CCH Journal of Tax Practice & Procedure (April-May, 2012)
Federal Income Taxation of the Individual Chapter 11 Debtor and the Bankruptcy Estate: Double Taxation -- Really?, Norton’s Bankruptcy Law Adviser (April, 2011, Co-Author: Frances Sheehy)
The Subprime Mortgage Debacle: A Tax Issue?, Norton’s Bankruptcy Adviser (March, 2009)
The Internal Revenue Service and Tax Opinions on Litigation Hazards: Not Work Product!, Tennessee Bar Journal (March, 2008)
The Hunt for Tax Accrual Workpapers, Tennessee CPA Journal (November, 2007)
Bankruptcy Tax Issues: The Conflict of Codes!, Enrolled Agents Journal (May-June, 2002)
Association of Insolvency and Restructuring Advisers
Chattanooga Tax Practitioners’ Club
Kentucky Federal Tax Institute
IRS National Tax Forums
Maryland Association of Certified Public Accountants
NYU Institute on Federal Taxation
Section on Taxation, American Bar Association
Southern Federal Tax Institute
Tennessee Federal Tax Institute
Tennessee Federal Tax Conference
Tennessee Society of Certified Public Accountants
Tennessee Society of Enrolled Agents
Wisconsin Bar Association
ABA Section on Taxation, Criminal and Civil Penalties Committee, Houston, TX, January 29, 2015
•Bankruptcy: The Judicial Answer To Unpaid Federal Tax Liabilities
•Discharge of Taxes in the Aftermath of McCoy
ABA Business Law Section, Webinar, May 19, 2015
•Discharge of Tax Liabilities In Bankruptcy: Late Filed Returns and The Internal Revenue Service
ABA Section on Taxation, Bankruptcy and Workout Committee, Phoenix, Arizona, January 23, 2014
•Dealing With State Tax Authorities In Bankruptcy: Unpaid Federal Tax Liabilities
•THE OFFICE OF PROFESSIONAL RESPONSIBILITY THE IRS COLLECTION PROCESS AND THE BANKRUPTCY WORLD
Florida Bar Association, Tax Section, Orlando, Florida, April 24, 2014
•IRS APPEALS -- Appeals Judicial Approach and Culture
•IRS Compliance and Appeals Issues
ABA Section of Taxation, Bankruptcy and Workout Committee, Washington, DC, May 8, 2014
•IRS Compliance and Appeals Issues -- The Collection Perspective
•Tax Priorities and Dischargeability: Application of Sections 507 and 503 of the Bankruptcy Code
American Law Institute, Washington, DC, October 15, 2014
•Bankruptcy: The Judicial Answer To Unpaid Federal Tax Liabilities
Tennessee Federal Tax Conference, Brentwood, TN, November 19, 2014
•Circular 230 and the Office of Professional Responsibility (OPR): Enforcement
•OPR: Director’s Update
Great Plains Federal Tax Institute (Nebraska CPAs), Omaha, Nebraska, December 4, 2014
•A Tax Map For The Bankruptcy Process – Tax Issues Only
•Using Bankruptcy To Provide Relief From Tax Debt
ABA Criminal Tax Controversy Institute, Las Vegas, NV, December 10, 2014
•Closing the Audit: The Options.
ABA Tax Section Mid-Year Meeting, Orlando, FL, January 25, 2013
•The Exit Strategy from Retirement Accounts for the Financially Challenged: The IRS Collection Process and Bankruptcy Protection
•IRS Collection & Bankruptcy Alternatives
•Tough Issues in Bankruptcy Tax and Annual Updates
ABA 2013 May Meeting, Washington, DC, May 10, 2013
A Conversation with the Office of the Chief Counsel, IRS and the Tax Division Department of Justice
TN Society of Certified Public Accountants, Chattanooga Tax Practitioners, Chattanooga, TN, July 12, 2013
The IRS Collection Process: The Taxpayer Advocate, and IRS 2012 “Fresh Start”
IRS Nationwide Tax Forum
August 20-22, 2013
•San Diego, CA
September 16-19, 2013
Tax Debt Relief in Bankruptcy
TSCPA – Tennessee Federal Tax Conference, Brentwood, TN, November 20-22, 2013
•The Internal Revenue Service Examination – How to Handle: Planning and Pitfalls
•The Internal Revenue Service’s Collection Due Process “Hearing”: A Misnomer? Litigating the Collection Process
30th Annual National Institute on Criminal Tax Fraud and 3rd Annual National Institute on Tax Controversy, Las Vegas, NV, December 11-13, 2013
Dialing for Dollars: The IRS Collection Process – Administrative and Judicial Solutions
ABA Section on Taxation, Bankruptcy and Workouts Committee 2012 Mid-Year Meeting, February 17, 2012 (Moderator and Prepared Materials)
Tax Litigation: Tax Court or Bankruptcy Court – When, Where, How and Why
ABA Section on Taxation and Bankruptcy and Workouts Committee, May 10-12, 2012 (Moderator and Prepared Materials)
•Top Ten Hot Button Issues – Bankruptcy Tax Procedural Issues* (*and Foot Faults) (A Panel Discussion)
•Bankruptcy, Collections and the Collection Due Process Appeal
ABA Section on Taxation and Section of Real Property, Trust and Estate Law – 2012 Joint Fall CLE Meeting, Boston, MA, September 14, 2012
When and How to Withdraw from Representation Consistent with the Ethics Rule
National Association of Consumer Bankruptcy Attorneys (NACBA), Amelia Island, FL, November 4-5, 2012
Top Ten “Hot Button” Issues* (*and Foot Faults) – Bankruptcy Tax Procedure (and a bit of Substance) (A Panel Discussion)
TSCPA – Tennessee Federal Tax Conference, Franklin, TN, November 14, 2012
Voluntary Disclosure: Definitions and Mechanics and the 2012 Offshore Voluntary Disclosure
ABA 29th Annual National Institute on Criminal Tax Fraud and 2nd National Institute on Tax Controversy, Los Vegas, NV, December 6-7, 2012
Administrative Tax Strategies and Techniques in a Recessionary Economy
ABA 2011 Midyear Meeting of Closely Held Businesses and Bankruptcy & Workouts, Boca Raton, FL, January 21, 2011
Treatment of the Secured Tax Claim in Bankruptcy
Chattanooga Tax Practitioners, Chattanooga, TN, April 20, 2011
The IRS Collection Process and the Bankruptcy Alternative
American Institute of CPAs (AICPA), Las Vegas, NV, May 5-6, 2011
Unpaid Federal Tax Liabilities, The IRS Collection Process and the Bankruptcy Alternative
TSCPA – Tennessee Federal Tax Conference, Brentwood, TN, November 16-18, 2011
Internal Revenue Service Criminal Tax Investigations: A Primer for “Civil” Tax Advisors
ABA 2010 Midyear Meeting of Closely Held Businesses and Bankruptcy & Workouts, San Antonio, TX, January 22, 2010
Tax and Bankruptcy Considerations When Representing Financially Distressed Entities and Their Owners
ABA Tax Section – State Bar of Wisconsin, Milwaukee, WI, March 12, 2010
Let’s Make A Deal With The IRS – OR – Is A Bankruptcy Discharge the Answer – Tax Implications: Workouts and Bankruptcy
TN Society of Enrolled Agents – TSEA Annual Tax Seminar, Brentwood, TN, May 20-21, 2010
Tax Issues in Bankruptcy
9th Annual NC/SC Tax Section, Kiawah Island, SC, May 28-30, 2010
Tax Issues in Bankruptcy
Maryland Association of Certified Public Accountants – Advanced Tax Institute, Baltimore, MD, November 2, 2010
Unpaid Federal Tax Liabilities
TN Society of Certified Public Accountants (TSCPA), 2010 Tennessee Federal Tax Conference, Franklin, TN, November 18, 2010
•Bankruptcy Taxation: The Tax Life Cycle of a Business Bankruptcy
•IRS Tax Penalties: “The Practical Approach” (A Panel Discussion)
•Voluntary Disclosure: Correcting Errors and Eliminating Criminal Prosecution
2009 IRS Nationwide Tax Forum
Federal Tax Treatment of Debt Workouts
Southern Federal Tax Institute, Atlanta, GA, October 19-23, 2009
IRS Collection Issues And The Bankruptcy Alternatives
ABA CLE Teleconference, October, 28, 2009
Let’s Make a Deal With the IRS – OR – Is Discharge the Answer?
Georgia Tax Forum, Savannah, GA, November 11-14, 2009
The IRS v. The Bankruptcy Code
Tennessee Federal Tax Conference, Brentwood, TN, November 11-18, 2009
IRS Collection Issues: Bankruptcy vs. IRS Administrative Options