Nicholas L. Roberti
Overview
Nicholas Roberti represents clients facing government actions, complex commercial disputes, and tax controversy matters. Nick is a goal-driven problem solver who understands how to navigate disputes across the legal spectrum.
Career & Education
- University of Virginia School of Law, J.D., 2022
editorial board member, Virginia Law & Business Review - Washington College, B.A., 2019
Phi Beta Kappa
- University of Virginia School of Law, J.D., 2022
- District of Columbia
- Courts of the State of New York
- U.S. District Court for the Southern District of New York
- U.S. District Court for the District of Columbia
- Honorable Judith C. McCarthy, United States District Court for the Southern District of New York, 2023–2024
Nicholas's Insights
Client Alert | 3 min read | 08.13.25
Faster Audits, More ADR: IRS Rolls Out Significant LB&I Changes
On July 23, 2025, the Internal Revenue Service (“IRS”) issued interim guidance for Large Business & International Division (“LB&I”) audit procedure. The IRS announced three major changes: (1) the Acknowledgement of Facts Information Document Request (“AOF IDR”) will be eliminated; (2) Accelerated Issue Resolution (“AIR”) applies to Large Corporate Compliance (“LCC”) cases; and (3) the IRS must conduct additional review before denying a taxpayer’s request to participate in the Fast Track Settlement (“FTS”). These changes reflect the IRS’s continued push to make its examinations “more efficient and current.”
Client Alert | 3 min read | 07.29.25
Meet the New Nationwide Injunction. Same as the Old Nationwide Injunction.
Publication | 07.23.25
Representative Matters
- Counseled a leading health care company in a tax dispute with the IRS.
- Represented a railroad company in an APA appeal in federal court.
- Advised a major argi-fintech company in an investigation by the DOJ.
- Advised an international petroleum and natural gas company on antitrust issues relating to information sharing.
- Represented a major pharmaceutical company in a multibillion-dollar breach of contract dispute.
Nicholas's Insights
Client Alert | 3 min read | 08.13.25
Faster Audits, More ADR: IRS Rolls Out Significant LB&I Changes
On July 23, 2025, the Internal Revenue Service (“IRS”) issued interim guidance for Large Business & International Division (“LB&I”) audit procedure. The IRS announced three major changes: (1) the Acknowledgement of Facts Information Document Request (“AOF IDR”) will be eliminated; (2) Accelerated Issue Resolution (“AIR”) applies to Large Corporate Compliance (“LCC”) cases; and (3) the IRS must conduct additional review before denying a taxpayer’s request to participate in the Fast Track Settlement (“FTS”). These changes reflect the IRS’s continued push to make its examinations “more efficient and current.”
Client Alert | 3 min read | 07.29.25
Meet the New Nationwide Injunction. Same as the Old Nationwide Injunction.
Publication | 07.23.25
Insights
Nicholas's Insights
Client Alert | 3 min read | 08.13.25
Faster Audits, More ADR: IRS Rolls Out Significant LB&I Changes
On July 23, 2025, the Internal Revenue Service (“IRS”) issued interim guidance for Large Business & International Division (“LB&I”) audit procedure. The IRS announced three major changes: (1) the Acknowledgement of Facts Information Document Request (“AOF IDR”) will be eliminated; (2) Accelerated Issue Resolution (“AIR”) applies to Large Corporate Compliance (“LCC”) cases; and (3) the IRS must conduct additional review before denying a taxpayer’s request to participate in the Fast Track Settlement (“FTS”). These changes reflect the IRS’s continued push to make its examinations “more efficient and current.”
Client Alert | 3 min read | 07.29.25
Meet the New Nationwide Injunction. Same as the Old Nationwide Injunction.
Publication | 07.23.25
