LITC Volunteer Training Litigating collection due process issues in Tax Court



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About the Program

The Center for Taxpayer Rights is bringing you training on litigation of tax collection issues particularly as these relate to low-income taxpayers. The focus will be on collection due process proceedings, both at the administrative level and as a litigation matter in the US Tax Court. Related topics include determining the validity of the assessment, issues associated with the administrative record, and the burgeoning litigation related to jurisdiction issues in the US Tax Court.

Meet the Speakers
Oliver Roberts
Oliver Roberts


Associate Jones Day

Oliver Roberts represents and advises clients on a variety of commercial contract, securities, arbitration, and business strategy matters. His experience includes winning an oral argument in a six-figure tax case before the Third Circuit Court of Appeals and advising clients in international and domestic contract disputes.

Oliver frequently publishes legal analyses on constitutional issues, including his recent article in the South Carolina Law Review titled, “The New Federalism Frontier in Marijuana Legalization and Decriminalization” (2021).

Oliver also maintains an active pro bono practice ranging from tenant housing to immigration matters.

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Robert Probasco
Robert Probasco


Senior Lecturer and Director Tax Dispute Resolution Clinic, Texas A&M University School of Law

I solve problems for taxpayers dealing with IRS audits and potential tax deficiencies, at all stages of a tax dispute, including audits, administrative appeals, refund claims, and litigation in the United States Tax Court, the United States Court of Federal Claims, or United States District Court. This work is performed through an academic low-income taxpayer clinic (LITC), where I teach the students tax procedure & practical skills and supervise their work. Our #TaxJustice Warriors get great results for our clients!

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Mary Michelle Gillum
Mary Michelle Gillum


Director Tennessee Taxpayer Project, Legal Aid Society of Middle Tennessee and the Cumberlands

Mary Michelle Gillum is the Director of the Legal Aid Society’s Low Income Taxpayer Clinic, also known as the Tennessee Taxpayer Project. Ms. Gillum, in conjunction with the University of Tennessee College of Law Legal Clinic and the Legal Aid Society, founded the Tennessee Taxpayer Project in 2000. Since 2000, the Tennessee Taxpayer Project has represented over 5,000 clients before the IRS and procured financial benefits totaling over $40,000,000. Ms. Gillum obtained a Bachelor of Science from the University of Tennessee in 1994 where she majored in Accounting and Business Law. In 2000, she obtained a Doctor of Jurisprudence from the University of Tennessee College of Law. She is admitted to practice in the United States Tax Court, United States Bankruptcy Court and United States District Court for the Eastern District of Tennessee. She litigates cases each year in the United States Tax Court and United States Bankruptcy Court. Ms. Gillum was lead counsel in Marlow v. Commissioner, a published case that outlined actions the government must take in verifying requirements of applicable law and administrative procedure have been met in a due process hearing, and in Vinatieri v. Commissioner, a published case affirming IRC 6334(a)(1 )(D) prohibits levy when a taxpayer is facing economic hardship, even if noncompliant in filing returns. Ms. Gillum also served as counsel on Lantz v. Commissioner, a case that went up to the Circuit Court of Appeals, ultimately changing the time period to request equitable innocent spouse relief from two to ten years. Ms. Gillum began working with the Legal Aid Society in 2000 with a full fellowship from Equal Justice Works (EJW). In September 2014, EJW named Ms. Gillum to the Equal Justice Works Alumna Hall of Fame. In 2004, she received the 8. Riney Green Award from the Tennessee Alliance for Legal Services, for outstanding efforts to promote collaboration among legal aid programs. She recently received the Tennessee Bar Association’s 2018 Ashley T. Wiltshire Public Service Attorney of the Year Award. Ms. Gillum is a member of the Tennessee Bar Association Faculty and provides continuing legal education seminars to attorneys throughout the state. The IRS regularly invites her to present training to examiners. She has also been invited to advise the Commissioner of the IRS on systemic issues related to low-income taxpayers. Ms. Gillum’s current practices includes federal income tax controversies, bankruptcy and collection defense.

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