Matthew L. Roberts, J.D., LL.M. 2595 Dallas Parkway, Suite 420

Frisco, TX 75034 Direct: 214.984.3658

Email: mroberts@freemanlaw.com

2595 Dallas Parkway, Suite 420 Frisco, TX 75034

TF: 855.676.1040 Office: 214.984.3410 Fax: 214.984.3409 www.FreemanLaw.com

Matthew L. Roberts, Principal Mr. Roberts is a Principal of the firm. He devotes a substantial portion of his practice to helping his clients successfully navigate and resolve their federal tax disputes, either administratively, or, if necessary, through litigation. As a trusted advisor, he has provided legal advice and counsel to hundreds of clients, including individuals and entrepreneurs, non-profits, trusts and estates, partnerships, and corporations. Having served nearly three years as an attorney-advisor to the Chief Judge of the United States Tax Court in Washington, D.C., Matt leverages his unique insight into government processes to offer his clients creative, innovative, and cost-effective solutions to their tax problems. In private practice, Matt has successfully represented clients in all phases of a federal tax dispute, including IRS audits, appeals, litigation, and collection matters. He also has significant experience representing clients in employment tax audits, voluntary disclosures, FBAR penalties and litigation, trust fund penalties, and penalty abatement and waiver requests. Often times, Matt has been engaged to utilize his extensive knowledge of tax controversy matters to assist clients in their transactional matters. For example, Matt has provided tax advice to businesses on complex tax matters related to domestic and international transactions, formations, acquisitions, dispositions, mergers, spin-offs, and liquidations. Matt received his Bachelor of Accountancy and his Master of Science in Taxation from the University of Mississippi. He received his law degree, summa cum laude, from the University of Mississippi School of Law, where he graduated in the top five percent of his law school class. During law school, Matt was an editor for the Mississippi Law Journal and also an executive board member of the Moot Court Board. After law school, he received an LL.M. (Master of Laws) in Taxation from New York University School of Law. He is a frequent speaker and author on complex tax matters, and his articles have been published in national and regional publications including the Journal of Tax Practice and Procedure and Tax Notes.

Professional Memberships and Affiliations • American Bar Association

o Section of Taxation • State Bar of Texas

o Tax Section • Dallas Bar Association

o Tax Section

Practices Tax Litigation IRS Administrative Practice Criminal & White-Collar Defense Int’l & Offshore Tax Compliance Business Litigation Probate Litigation Tax Planning Education

New York University, LL.M. (Taxation) The University of Mississippi School of

Law, summa cum laude, J.D. The University of Mississippi, M.S. in

Taxation The University of Mississippi, B.S. in Accountancy Bar Admissions State Bar of Texas State Bar of Mississippi United States Court of Appeals

for the Fifth Circuit United States District Court for

the Northern District of Texas, Eastern District of Texas, and Southern District of Texas

United States Tax Court

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Publications

• Co-Author, “Whistleblowers Face Self-Employment Tax Worries Too,” Tax Notes Federal, December 9, 2019. • Co-Author, “New IRS Tax Audit Rules and Divorce Agreements,” Dallas Bar Association Headnotes: Family Law, September

2018. • Co-Author, “The New Partnership Audit Rules – Turning the Taxation of Partnerships Upside Down,” Petroleum Accounting

and Financial Management Journal, Summer 2016. • Co-Author, “Buckle Your Seatbelts: Employment Taxes are Back in Vogue and it will be a Bumpy Ride – the IRS and

Department of Justice Tax Division are on the Hunt,” Journal of Tax Practice and Procedure, June – July 2015. • Author, “Transmuting Mississippi’s Current Transmutation Doctrines: Establishing Clear and Consistent Precedents to

Property Division,” 80 MISS. L. J. 709 (2010). Speaking Engagements • “Coronavirus Relief: The PPP and the New Loan Forgiveness Guidance,” CPA Academy Webinar, May 21, 2020. • “IRS Collection Representation in the Wake of COVID-19,” CPA Academy Webinar, April 30, 2020. • “COVID-19 Deep Dive,” TXCPA Webinar, April 13, 2020. • “Coronavirus and Recent Tax and Business Relief: What You Need to Know Now,” TXCPA Dallas Webinar, April 8, 2020. • “Coronavirus and Recent Tax and Business Relief: What You Need to Know Now,” Dallas Bar Association Webinar, April

7, 2020. • “Partnership Tax Audit and Collection Rules Including Final and Reproposed Regulations,” 2019 Corpus Christi

Chapter/TSCPA Tax Conference, February 1, 2019. • “New Partnership Audit Rules: What They Mean to Partnerships and Tax Professionals,” Lorman Live Webinar, March 16,

2018. • “New Partnership Audit Rules: What They Mean to Partnerships and Tax Professionals,” Dallas Bar Association Tax

Section, December 4, 2017. • “The New Partnership Audit Rules,” First Bank & Trust Seminar, November 9, 2016. • “Taxing Times: Planning and Defending in an Uncertain Tax and IRS Environment,” Firm Conference, October 25, 2016. • “Civil and Criminal Employment Tax Enforcement Efforts: Employers Beware,” Firm Conference, November 3, 2015.

Representative Matters

• Represented numerous clients in obtaining full abatement or waiver of trust fund recovery penalties. • Represented various clients in obtaining full abatement or waiver of federal tax penalties, including failure-to-file and failure-

to-pay penalties and international reporting obligation penalties including Forms 5471, 5472, 3520, 3520-A, 8938, and FBAR. • Filed petitions and litigated over 30 cases in the United States Tax Court. • Represented innocent spouses in obtaining full innocent spouse relief under I.R.C. § 6015. • Represented clients in Collection Due Process (CDP) hearing matters, including representation at the IRS Independent

Office of Appeals and at the United States Tax Court. • Counseled clients on unfiled tax return matters including preparation and submissions of Offshore Voluntary Disclosure

Program (OVDP) materials, Streamlined Filing Compliance Procedure materials, and other voluntary disclosure programs. • Represented numerous non-profits with respect to IRS examination for proposed self-dealing penalties and other applicable

non-profit penalties. • Counseled various clients on IRS collection alternatives, resulting in significant reductions in tax debts for clients due to

successful submissions of offers-in-compromise. • Senior associate in False Claims Act and Anti-Kickback Statute qui tam health care fraud lawsuit, U.S. ex rel. Dean v. Paramedics

Plus, LLC, et al., No. 4:14-CV-203 (E.D. Tex.), where Government sought damages in excess of $300 million against client. • Lead counsel in will and probate contest, resulting in over $1.5 million settlement award for client. • Prepared complex tax opinions and provided tax advice to clients on tax effects of litigation settlement and judgment awards. • Provided legal counsel to clients on tax effects and structuring of domestic and international business transactions, including

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formations, acquisitions, dispositions, mergers, spin-offs, and liquidations.

• Advised clients with international business operations on I.R.C. § 951A GILTI inclusion and recommended various courses of action including I.R.C. § 962 election or use of corporate blocker.

• Successfully represented client in FBAR federal district court litigation. • Provided legal counsel to numerous clients in structuring tax-free partnership divisions and tax-free corporate spin-offs. • Represented client in disputed Irrevocable Life Insurance Trust (ILIT) in IRS Independent Office of Appeals, resulting in

federal estate tax savings in excess of $1 million. • Represented client in federal gift tax dispute with IRS, resulting in federal gift tax savings in excess of $500,000. • Represented clients in IRS “eggshell” audits, resulting in no criminal referrals. • Represented numerous clients where IRS sought to classify horse, cattle, and farming activities as hobby losses under I.R.C. §

183. • Provided legal counsel to clients on deferred compensation arrangements under I.R.C. § 409A. • Analyzed and provided legal advice on Buy-Sell Agreement for purchase of approximately $10 million company. • Provided legal advice on tax effects of the sale of intangible property, including copyrights, trademarks, goodwill, and patents. • Prepared organizational documents and tax-exempt status applications for non-profit entities. • Defended clients with respect to disputed employment classifications (employee vs. independent contractor) before the IRS

and Texas Workforce Commission. • Provided legal advice to clients and CPAs on new centralized partnership audit regime under Bipartisan Budget Act (BBA) of

2015. • Provided legal advice to client on tax effects of certain oil and gas drilling activities in the State of Texas. • Provided legal advice to numerous clients on federal withholding and reporting obligations with respect to certain outbound

transactions. • Counseled clients with respect to tax effects of Foreign Investment in Real Property Tax Act (FIRPTA). • Assisted clients in various tax free-reorganizations, both foreign and domestic, including those under I.R.C. § 368(a)(1)(A)

(statutory mergers or consolidations); I.R.C. § 368(a)(1)(B) (stock-for-stock); I.R.C.§ 368(a)(1)(C) (stock-for-asset); I.R.C. § 368(a)(1)(D) (divisions); and I.R.C. § 368(a)(1)(F) (reorganizations).

• Represented clients in obtaining full abatement or waiver of information return reporting penalties, such as Forms W-2, Forms W-3, and Forms 1099.

• Represented oil and gas pipeline company in employment tax audit, resulting in significant reductions in employment tax and employment tax penalties.

• Represented cryptocurrency client with respect to purported failure to follow FinCEN anti-money laundering statutes. • Prepared sentencing memo for client accused of criminal tax evasion, resulting in probation and no jailtime for client.