Robert H. Wellen

Bob's practice focuses on corporate tax issues, with particular emphasis on corporate group restructurings, spin-offs, and M&A transactions. He works with clients, as well as with other law firms and accounting firms, to negotiate and implement the tax aspects of these transactions, to secure IRS private letter rulings, and to develop legal and policy positions on corporate tax matters. He also represents clients in tax controversies and provides arbitration and expert witness services in commercial disputes involving tax issues.

From 2015 to 2023, Bob served as Associate Chief Counsel (Corporate) of IRS. In that position, he supervised 50 lawyers responsible for corporate tax matters, including drafting regulations, revenue rulings, and other published guidance, handling technical aspects of cases in examination, IRS Appeals and litigation, and issuing private letter rulings on corporate transactions. During his tenure at IRS, significant developments occurred in the taxation of M&A transactions, internal restructurings, and spin‑offs. In addition, a revamp of the private ruling program improved timeliness, consistency of outcomes, and attention to policy.

Prior to his service at IRS, Bob spent 40 years in private practice of tax law in Washington – including 22 years as a partner at Ivins, Phillips & Barker.

Bob grew up in Jersey City, New Jersey. He received his B.A. from Yale College, his J.D. from Yale Law School, and his LL.M in Taxation from Georgetown Law Center. Before beginning his career in private practice, he served on active duty in the Navy JAG Corps for three and a half years. 

Practice Areas

Education

Georgetown University Law Center, LL.M. in Taxation, 1975

Yale Law School, J.D., 1971

Yale College, B.A.,1968, Phi Beta Kappa; Magna Cum Laude; High Honors in English

Bar & Court Admissions

Colorado

Connecticut

District of Columbia

Government Service

Internal Revenue Service, Associate Chief Counsel (Corporate) 2015-2023

Judge Advocate General’s Corps, U.S. Naval Reserve, active duty 1971-1975

Memberships & Affiliations

American Bar Association Tax Section: Chair, Corporate Tax Committee; Section Council Assistant Secretary

American College of Tax Counsel

District of Columbia Bar Tax Community

Federal Bar Association

Honors & Awards

Chambers USA (prior to serving as a senior IRS official)

Best Lawyers in America 1997 - present