Robert H. Albaral

Robert Albaral routinely represents taxpayers at various stages of Federal and International state tax controversies, including audit, administrative appeals and judicial proceedings. His professional affiliations include the American Bar Association, the US Supreme Court, the State Bar of Texas, the US Tax Court, the Federal District Court in the Northern and Southern Districts of Texas, the United States Bankruptcy Court, as well as Fifth and Seventh Circuit Courts of Appeals.

He has held significant management positions within the Firm and is the immediate past Chair of the North America Tax Dispute Resolution Committee and a member of the Global Tax Dispute Resolution Steering Committee. He is a member of the Firm’s Diversity and Inclusion Committee and currently the Managing Partner of the Dallas office.

Mr. Albaral regularly assists clients in the resolution of tax through administrative audit and appeals, and if necessary, through litigation. His practice also covers the resolution of domestic and international issues through all phases, and includes the use of alternative dispute resolution tools such as Fast Track Settlement, Appeals Mediation ,Early Referrals to Appeals and Competent Authority.

Education:

• Southern Methodist University (J.D.) (1984)
• University of Texas at Austin (Bachelor of Business Administration) (1981)

Admissions:

• U.S. District Court, Southern District of Texas (2015)
• U.S. Supreme Court (2005)
• U.S. Court of Federal Claims (2005)
• U.S. Court of Appeals, Fifth Circuit (2004)
• U.S. Court of Appeals, Seventh Circuit (1993)

Professional Associations and Memberships : State Bar of Texas

Representative Legal Matters:

• Tucker v. Commissioner, 114 T.C.M. (CCH) 326, Dkt. No. 12307-04 ( 2017) (economic substance issue with a determination that no penalties are applicable and the exclusion of a serial government expert witness’ testimony and report).
• Pilgrim’s Pride Corp. v. Commissioner, 779 F.3d 311 (5th Cir. 2015) (successfully reversed Tax Court opinion regarding character of stock abandonment loss).
• Pilgrim’s Pride Corporation and Subsidiaries v. Commissioner of Internal Revenue, U.S. Tax Court Docket No.16972-10, (various issues including captive insurance and methods of accounting).
• In re Pilgrim’s Pride Corporation, et al., United States Bankruptcy Court for the Northern District of Texas, Fort Worth Division, Case No. 08-45664 (special tax counsel in bankruptcy proceeding).