About Rogelio Villageliu

Rogelio Villageliu is a highly experienced tax attorney, having served over 40 years in the IRS Office of Chief Counsel. Rogelio has litigated numerous U.S. Tax Court cases and handled a multitude of complex docketed and non-docketed tax matters. His distinguished career has given him invaluable knowledge and experience in all areas of business and individual tax law with an emphasis on large business issues.

Significant assignments include serving as IRS Lead Industry Counsel for the Food, Beverages, and Hospitality industries; Lead Industry Counsel for the Restaurant industry; Lead Industry Counsel for the Agricultural and Biofuels industries; Lead Industry Counsel for the Cooperative industry; IRS Counsel, Area 3 Civil Fraud Penalty Coordinator, Tax Accrual Work-Papers Coordinator and FBAR Coordinator; member of the Restaurant Industry Issue Resolution team; member of the Small Wares Industry Issue Resolution team; member of the Small Wares Industry Director’s Directive team; Counsel for the Gift Card/Certificates Tier II Issue Management Group; Counsel to the Tier II Upfront License Fees and Milestone Payments Group; member of the S Corporations and Cooperatives Industry Practice Group; member of the foreign-based documentation Issue Practice Network; member of the national regulation team working on drafting regulations under IRC Section 199A; and Special Assistant United States Attorney (SAUSA) for IRS bankruptcy tax law issues.


  • IRS Counsel, Fayette G. Taylor Memorial National Award for Excellence in General Litigation
  • Recipient team member of IRS Counsel “Outstanding Litigation Team” of the year national award
  • Albert Gallatin Award
  • IRS Special Act Award and Superior Performance awards
  • IRS Regional Counsel Certificate of Commendation

Speaking Engagements

  • LB&I S Corporations & Cooperatives IPG Overview of Cooperative Tax Law
  • IRC Section 1245/Section 1250 Cost Segregation Studies
  • Application of the Rules of Evidence to Computerized Data
  • New Guidance on IRC Section 41 Credit for Research & Development
  • Vendors Allowances, Product Costing, Food, Beverage, and Hospitality, Cooperatives, and Biotechnology Issues
  • American Job Creation Act Section 199
  • Everything You Need to Know About Cost Segregation

Top Practice Areas


  • Master of Laws (Taxation) with high honors, Chicago-Kent College of Law; Received the CALI Estate Planning Award

  • Juris Doctor, Columbia Law School

  • Parker Recognition of Achievement in International and Foreign Law with honors, Columbia Law School

  • Bachelor of Arts with distinction, Phi Beta Kappa, and recipient of the Honors Certificate of Achievement, University of Iowa

  • Certificate in Advanced Accounting with high honors, College of DuPage

  • Post-Baccalaureate Certificate in Accounting, Simpson College

Admissions and Certifications

  • Admitted to the U.S. Tax Court and licensed to practice law in Illinois

  • Illinois Licensed Certified Public Accountant

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