Robert J. Kovacev

Robert J. Kovacev's practice focuses on federal tax controversy and tax litigation. He combines extensive first-chair litigation skills with substantive tax knowledge to represent taxpayers in high-profile, high-stakes tax disputes against the Internal Revenue Service (IRS), both at the administrative level and in litigation. These disputes include international tax and transfer pricing issues, the research tax credit, the Section 199 domestic production activities deduction, alternative energy tax credits, and the economic substance doctrines. Mr. Kovacev has more than two decades of experience representing clients in Tax Court and in federal district and appellate courts. Recognized by Forbes for having one of the top tax-related Twitter accounts, Mr. Kovacev is a leader in the emerging field of taxation of robotics and artificial intelligence, and he frequently writes and speaks on the topic. Clients in Chambers USA noted, "Robert Kovacev's strong tax technical skills and extensive tax controversy experience have made him a trusted advisor."

Prior to joining Miller & Chevalier, Mr. Kovacev was a partner at a global law firm. Before entering private practice, he was a senior litigation counsel in the Tax Division of the U.S. Department of Justice (DOJ), where he was lead trial counsel for the IRS in some of the largest and most complex civil tax cases in the nation. In that position, Mr. Kovacev worked closely with the IRS's Large Business & International (LB&I) Division and top management of the Tax Division to shape litigation strategy on high-priority tax enforcement issues. These cases involved cross-border transactions, Section 482 disputes, Section 199 deductions, research credits, foreign tax credits, corporate reorganizations and acquisitions, and IP valuations, with claimed tax benefits ranging from $10 million to more than $1 billion.