TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

I recently blogged about Silver Moss Properties, LLC v. Commissioner, 165 T.C. No. 3 (August 21, 2025), where the Tax Court held that the Seventh Amendment right to jury trial did not apply to suits against the United States, which had not consented to jury trial in TEFRA partnership proceedings, and that the public right exception to the right to jury trial applies to the fraud penalty under Internal Revenue Code (“IRC”) §6663(a). On December 15, 2025, the Tax Court issued another regular opinion1 discussing whether a TEFRA partnership is entitled to a jury trial on a penalty. Riddle Aggregates, LLC v. Commissioner, 165 T.C. No. 12. Since the Tax Court found the case worthy of a regular rather than a memorandum opinion, I decided to write a blog on the case.

Click Here for Full Article

Robert S. Horwitz is a Principal of Hochman Salkin Toscher Perez P.C. and has over 40 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year. He was previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section.

Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board.

Mr. Horwitz was previously a trial attorney, US Department of Justice Tax Division and an Assistant United States Attorney, Tax Division, Los Angeles. He was the 2022 recipient of the Joanne M. Garvey Award for lifetime achievement in and outstanding contributions to the field of tax law and the 2021 recipient of the Orange County Bar Association, Tax Chair Recognition award.

For more information, please contact Robert S. Horwitz at horwitz@taxlitigator.com

Did you or your client move to Puerto Rico, or are you considering a move? Many Americans have taken advantage of the very favorable tax treatment available to Puerto Rican residents, but not all of them have complied with the strict requirements for favorable tax treatment. But, related to the number of Americans who claim Puerto Rican tax residency, the small handful of civil and criminal tax matters may have given taxpayers the impression that the IRS either doesn’t care or can’t get its act together to address any improper claims of Puerto Rican residency. But that appears to be changing, thanks to a Government Accountability Office (GAO) audit that laid bare the IRS’s inadequacies.

Click Here for Full Article

For more information, please contact Steven Toscher at toscher@taxlitigator.com.

Evan Davis has been a Principal at Hochman Salkin Toscher Perez P.C. since November 2016. Mr. Davis handles federal and state criminal and civil tax investigations/exams, white-collar defense, cryptocurrency clients, and civil and criminal appellate matters including having litigated the In re Grand Jury attorney-client privilege matter before the US Supreme Court in 2023. He is also a Fellow of the American College of Trial Counsel

Before joining the firm in 2016, Evan spent nearly 20 years with the US Department of Justice. He was first a civil trial attorney with DOJ’s Tax Division, then an Assistant U.S. Attorney in the C.D. Cal’s Tax Division handling civil and criminal tax cases and, finally, a criminal AUSA in the USAO’s Major Frauds Section handling white-collar, tax, and other fraud cases through jury trial and appeal. He served as the Bankruptcy Fraud coordinator, Financial Institution Fraud Coordinator, and Securities Fraud coordinator. His awards include the U.S. Attorney General’s Distinguished Service Award for Evan’s work on the $16 Billion RMBS settlement with Bank of America.

For more information, please contact Evan Davis at davis@taxlitigator.com.

Philipp Behrendt is an Associate at Hochman Salkin Toscher Perez P.C., licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Philipp is a Liaison to the Young Lawyer Committee for the ABA Tax Section’s Civil and Criminal Tax Penalties Committee and served on the Beverly Hills Bar Association’s Barristers Board of Governors from 2022 to 2023. Philipp is the Chair of the Beverly Hills Bar Association’s Tax Section, a Liaison.

For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.

The IRS Criminal Investigation’s FY 2025 Annual Report was just issued and it tells practitioners where CI spent time, what CI measured, and where CI believes it produced results. Unfortunately, it does not tell us where CI is going –but it does give us some clues and reflects a vibrant CI with significant accomplishments for 2025. (IRS-CI Annual Report 2025, pp. 2–4).

Click Here for Full Article

For more information, please contact Steven Toscher at toscher@taxlitigator.com.

Sandra R. Brown is a Principal of Hochman Salkin Toscher Perez P.C., where her practice focuses on criminal tax investigations, grand jury matters, litigation, and sentencing matters as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals and litigation. Ms. Brown’s extensive experience and successes have included many notable cases including two U.S. Supreme Court decisions, numerous 9^th Circuit rulings and numerous favorable administrative resolutions for taxpayers involved in IRS investigations and audits.

Prior to joining the firm in 2018, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney, and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California; where, with 27 years as a trial lawyer, she personally litigated over 2,000 tax cases on behalf of the United States.

Ms. Brown obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax Counsel, Vice-Chair of the ABA’s Section of Taxation’s Criminal and Civil Tax Penalties Committee, Co-Chair of the UCLA Tax Controversy Institute, Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference, an ABA Loretta Collins Argrett Fellowship Mentor, and is a frequent lecturer and author on tax controversy topics, including international compliance and criminal tax matters. Ms. Brown has been recognized as one of California’s top 100 leading women lawyers, the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award, Chambers High Net Worth in Tax and Tax Fraud, and an honoree of the inaugural Lawdragon 500 Leading Global Tax Lawyers.

For more information, please contact Sandra R. Brown at brown@taxlitigator.com

Philipp Behrendt is an Associate at Hochman Salkin Toscher Perez P.C., licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Philipp is a Liaison to the Young Lawyer Committee for the ABA Tax Section’s Civil and Criminal Tax Penalties Committee and served on the Beverly Hills Bar Association’s Barristers Board of Governors from 2022 to 2023. Philipp is the Chair of the Beverly Hills Bar Association’s Tax Section, a Liaison.

For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.

Rule 12(b) of the Federal Rules of Civil Procedure allows a defendant to raise certain defenses in its responsive pleading or by motion, including under 12(b)(6), failure to state a claim upon which relief can be granted. A 12(b)(6) motion was a favorite motion of attorneys of the late Tax Division to get rid of cases that were frivolous or time barred. The tables were turned on the Government in United States v. Phelps, Case No. 7:25-CV-241-BO-BM (ED NC 11/18/2025). As a result, due to inartful pleading and a failure to move to amend the complaint, the Government’s suit to collect $24 million in taxes, penalties and interest was dismissed with prejudice.

Click Here for Full Article

Robert S. Horwitz is a Principal of Hochman Salkin Toscher Perez P.C. and has over 40 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year. He was previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section.

Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board.

Mr. Horwitz was previously a trial attorney, US Department of Justice Tax Division and an Assistant United States Attorney, Tax Division, Los Angeles. He was the 2022 recipient of the Joanne M. Garvey Award for lifetime achievement in and outstanding contributions to the field of tax law and the 2021 recipient of the Orange County Bar Association, Tax Chair Recognition award.

For more information, please contact Robert S. Horwitz at horwitz@taxlitigator.com

We are pleased to announce that Michel R. Stein along with Thomas Giordano-Liscari (Greenberg Glusker) will be speaking at the upcoming Barbri webinar on IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process, Wednesday, December 10, 2025, 10:00 a.m. – 11:30 a.m. (PST).

This webinar will provide tax professionals and advisers with an in-depth discussion of the IRS examination of taxpayers living abroad. The panel will focus on Section 965 transition tax, exit tax, and critical issues for non-filers; guide tax practitioners through the examination process; and explain best practices to withstand the ongoing scrutiny of these taxpayers’ returns.

Click Here for More Information

Michel R. Stein, a principal of Hochman Salkin Toscher Perez P.C., is a nationally recognized tax attorney with nearly 30 years of experience in tax controversy and planning for individuals and business entities. He is widely respected for his ability to resolve complex and sensitive tax controversies before the Internal Revenue Service and the California Franchise Tax Board, including matters involving significant civil and criminal exposure, and is a trusted resource to clients and advisors navigating the most challenging areas of federal and state tax law. His commentary and insights have been featured in leading tax publications, webinars, and media outlets addressing emerging issues in tax enforcement and policy.

Mr. Stein has represented hundreds of clients in civil tax examinations, administrative appeals, and litigation before the U.S. Tax Court, U.S. District Courts, California Superior Court, and the U.S. Courts of Appeals. He routinely advises and defends clients in matters involving California Residency, Digital Assets and Cryptocurrency Investigations, High-Net-Worth Taxpayer Compliance and Examination, Domestic and International Tax Compliance, Voluntary Disclosures and Streamlined Filings, Challenges to Listed and Reportable Transactions, Partnership Tax and Audit Rules, Employment Tax and Worker Classification Issues, as well as tax controversies arising from Complex Real Estate and Business Transactions.  

Mr. Stein began his legal career as an Attorney Advisor to Special Trial Judge Larry Nameroff of the U.S. Tax Court and is a Certified Specialist in Taxation Law by the State Bar of California.

For more information, please contact Michel R. Stein at stein@taxlitigator.com.

We are pleased to announce that Sandra R. Brown will be speaking at the upcoming PLI Institute seminar on Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules That Every Tax Advisor Should Know at Sofitel Los Angeles, December 10, 2025, 4:45 p.m. – 5:45 p.m.  Sandra will be joined by Bradley M. Seltzer and Andrew Weiner in a lively discussion about the ethical rules and potential pitfalls tax professionals face when advising clients and responding to the IRS, as well as potential ethical risks from the (Mis) use of AI in legal filings.

Click Here for Additional Information

Sandra R. Brown is a Principal of Hochman Salkin Toscher Perez P.C., where her practice focuses on criminal tax investigations, grand jury matters, litigation, and sentencing matters as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals and litigation. Ms. Brown’s extensive experience and successes have included many notable cases including two U.S. Supreme Court decisions, numerous 9^th Circuit rulings and numerous favorable administrative resolutions for taxpayers involved in IRS investigations and audits.

Prior to joining the firm in 2018, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney, and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California; where, with 27 years as a trial lawyer, she personally litigated over 2,000 tax cases on behalf of the United States.

Ms. Brown obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax Counsel, Vice-Chair of the ABA’s Section of Taxation’s Criminal and Civil Tax Penalties Committee, Co-Chair of the UCLA Tax Controversy Institute, Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference, an ABA Loretta Collins Argrett Fellowship Mentor, and is a frequent lecturer and author on tax controversy topics, including international compliance and criminal tax matters. Ms. Brown has been recognized as one of California’s top 100 leading women lawyers, the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award, Chambers High Net Worth in Tax and Tax Fraud, and an honoree of the inaugural Lawdragon 500 Leading Global Tax Lawyers.

For more information, please contact Sandra R. Brown at brown@taxlitigator.com

We are all looking forward to the ABA Tax Section 2025 Criminal Tax Fraud and Tax Controversy Conference next week, December 11-13, 2015, in Las Vegas, where there will be record attendance and an excellent line up of cutting-edge programs.

Conference Co-Chair Steven Toscher will be introducing former IRS Commissioners Charles Rettig and Danny Werfel who will discuss What Else Can We Do: Tax Controversy Practice in Challenging Times along with introducing Saturday’s closing panel, Non-Traditional Tax Advocacy. 

Conference Co-Chair Sandra R. Brown will moderate the much anticipated Criminal Tax Enforcement Priorities panel. You also don’t want to miss Evan Davis moderating the Sentencing Advocacy: Tips and Strategies for Both Post-Trial and Post-Plea Disposition panel and Melissa Briggs moderating the Jury Instructions, Expert Witnesses, and Evidentiary Objections panel.

We hope you will join us in Vegas!

Click Here for Additional Registration Information

Steven Toscher is the Managing Principal of the law firm, who specializes in civil and criminal tax controversy and litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization, a Fellow of the American College of Tax Counsel and has received an “AV” rating from Martindale Hubbell. Mr. Toscher serves as Co-Chair of the UCLA Tax Controversy Institute and Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference. Mr. Toscher is a frequent lecturer and author on tax controversy and litigation topics and is a co-author of the BNA Portfolio, Tax Crimes. Mr. Toscher was the 2018 recipient of the Joanne M. Garvey Award, given annually to recognize lifetime achievement and outstanding contributions to the field of tax law by a senior member of the California tax bar. Mr. Toscher is also the recipient the USD School of Law Richard Carpenter Excellence in Tax Award. In 2024 Mr. Toscher was the recipient of the prestigious Jules Ritholz Memorial Merit Award presented by the Civil and Criminal Tax Penalties Committee of the Taxation Section of the American Bar Association, recognizing tax lawyers who have demonstrated outstanding dedication, achievement and integrity in the field of civil and criminal tax controversies. 

For more information, please contact Steven Toscher at toscher@taxlitigator.com.

Sandra R. Brown is a Principal of Hochman Salkin Toscher Perez P.C., where her practice focuses on criminal tax investigations, grand jury matters, litigation, and sentencing matters as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals and litigation. Ms. Brown’s extensive experience and successes have included many notable cases including two U.S. Supreme Court decisions, numerous 9^th Circuit rulings and numerous favorable administrative resolutions for taxpayers involved in IRS investigations and audits.

Prior to joining the firm in 2018, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney, and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California; where, with 27 years as a trial lawyer, she personally litigated over 2,000 tax cases on behalf of the United States.

Ms. Brown obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax Counsel, Vice-Chair of the ABA’s Section of Taxation’s Criminal and Civil Tax Penalties Committee, Co-Chair of the UCLA Tax Controversy Institute, Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference, an ABA Loretta Collins Argrett Fellowship Mentor, and is a frequent lecturer and author on tax controversy topics, including international compliance and criminal tax matters. Ms. Brown has been recognized as one of California’s top 100 leading women lawyers, the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award, Chambers High Net Worth in Tax and Tax Fraud, and an honoree of the inaugural Lawdragon 500 Leading Global Tax Lawyers.

For more information, please contact Sandra R. Brown at brown@taxlitigator.com

Evan J. Davis has been a Principal at Hochman Salkin Toscher Perez P.C. since November 2016. Mr. Davis handles federal and state criminal and civil tax investigations/exams, white-collar defense, cryptocurrency clients, and civil and criminal appellate matters including having litigated the In re Grand Jury attorney-client privilege matter before the US Supreme Court in 2023. 

He is also a Fellow of the American College of Trial Counsel.Before joining the firm in 2016, Evan spent nearly 20 years with the US Department of Justice. He was first a civil trial attorney with DOJ’s Tax Division, then an Assistant U.S. Attorney in the C.D. Cal’s Tax Division handling civil and criminal tax cases and, finally, a criminal AUSA in the USAO’s Major Frauds Section handling white-collar, tax, and other fraud cases through jury trial and appeal. He served as the Bankruptcy Fraud coordinator, Financial Institution Fraud Coordinator, and Securities Fraud coordinator. His awards include the U.S. Attorney General’s Distinguished Service Award for Evan’s work on the $16 Billion RMBS settlement with Bank of America.

For more information, please contact Evan Davis at davis@taxlitigator.com.

Melissa Briggs is a Principal of the law firm Hochman Salkin Perez P.C. where she represents clients in civil and criminal tax litigation as well as tax investigations. She has over twenty years of litigation experience, including over 16 years combined experience as an Assistant United States Attorney for the Central District of California, Tax Division, and an Appellate Attorney in the United States Department of Justice, Tax Division, Appellate Section.  

For more information, please contact Melissa Briggs at briggs@taxlitigator.com.

We are pleased to announce that Dennis Perez, Robert S. Horwitz and Sebastian Voth will be speaking at the upcoming CalCPA Tax Talk webinar on Office of Tax Administration: Handling a Case Before California Office of Tax Appeals, Tuesday, December 9, 2025, 9:00 a.m. – 10:30 a.m. (PST).

This webinar will guide tax professionals and advisers on the stages of a California income tax case from preparation for the audit, through protesting an NPA, appealing to the Office of Tax Appeals (OTA), settlement with the FTB, and the trial of a case before the OTA. It will help you learn what you need to know to represent your client effectively with the FTB, what needs to be done to successfully settle a case with FTB’s Settlement Bureau, and representing your client before the OTA, including briefing, discovery and a hearing before a three administrative law judge panel.

Click Here for More Information

For over thirty-eight (38) years Dennis Perez has been representing clients in civil and criminal tax litigation and tax disputes and controversies before the Internal Revenue Service and all the California taxing agencies. Dennis was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in Los Angeles, California. He is a Certified Tax Specialist, California State Bar Board of Certification and is also a Fellow of the American College of Tax Counsel. He frequently lectures on advanced civil and criminal tax topics at seminars and before national, state and local bar associations and accountancy groups. He is a co-author of the BNA Portfolio, Tax Crimes, has served as the Chair of the Los Angeles Lawyer Magazine Editorial Board and is the first recipient of the Los Angeles Lawyer Sam Lipsman Service Award for outstanding service to the Los Angeles Lawyer Magazine. He is past Chair of the Tax Procedure and Litigation Committees of the Taxation Sections of the State Bar of California and the Los Angeles County Bar Association. Dennis is past President of the Alumni Board for the UCLA School of Law and has served as an Adjunct Professor, Golden Gate University, Graduate School of Taxation. 

For more information, please contact Dennis Perez at perez@taxlitigator.com.

Robert S. Horwitz is a Principal of Hochman Salkin Toscher Perez P.C. and has over 40 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year. He was previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section.

Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board.

Mr. Horwitz was previously a trial attorney, US Department of Justice Tax Division and an Assistant United States Attorney, Tax Division, Los Angeles. He was the 2022 recipient of the Joanne M. Garvey Award for lifetime achievement in and outstanding contributions to the field of tax law and the 2021 recipient of the Orange County Bar Association, Tax Chair Recognition award.

For more information, please contact Robert S. Horwitz at horwitz@taxlitigator.com

Sebastian Voth is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax investigations, litigation and appeals, and complex tax matters. Prior to entering private practice, Mr. Voth served for 15 years at the Internal Revenue Service including most recently as a Special Trial Attorney with the IRS Office of Chief Counsel’s Strategic Litigation Division leading trial teams in all phases of litigation before the Tax Court. During his tenure with the IRS, Mr. Voth served on the leadership team of the nationwide IRS Counsel mentoring program and mentored numerous IRS attorneys. He is the recipient of two Lucite Awards for significant Tax Court opinions and received a 2024 Special Act Award (Strategic Litigation), the 2023 Nationwide Innovator of the Year (LB&I), the 2022 Nationwide Special Trial Attorney of the Year (SB/SE), the 2017 U.S. Department of the Treasury Outstanding Litigator and the 2017 Nationwide Attorney of the Year (SB/SE). Serving as a Special Trial Attorney, Mr. Voth handled some of the IRS’s most significant and complex litigation matters.

For more information, please contact Sebastian Voth at voth@taxlitigator.com

We are pleased to announce that four of our attorneys will be speaking at the upcoming USC Gould School of Law 2026 Tax Institute, January 26-28, 2026 at the Sheraton Grand, Los Angeles on the following key topics:

Sandra R. Brown
A Conversation with the IRS Criminal Investigation Special Agent-In-Charge for the Los Angeles Field Office

Robert S. Horwitz and Philipp Behrendt
Employee Retention Credit Enforcement

Sebastian Voth
Valuation in Tax Cases: The Importance of Getting it Right

The Institute is three days and covers a wide range of substantive tax topics, including corporate tax planning, partnerships, real estate, estate planning and enforcement. Since 1948, the USC Gould School of Law Tax Institute has been the essential three-day event for tax professionals, providing an in-depth examination of the hottest tax law issues and the latest business perspectives. Join more than 60 experienced speakers from across the nation and internationally for the Institute’s conference, which will be hybrid this year (in-person audience and speakers with a virtual broadcast).

Click Here for More Information

Sandra R. Brown is a Principal of Hochman Salkin Toscher Perez P.C., where her practice focuses on criminal tax investigations, grand jury matters, litigation, and sentencing matters as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals and litigation. Ms. Brown’s extensive experience and successes have included many notable cases including two U.S. Supreme Court decisions, numerous 9^th Circuit rulings and numerous favorable administrative resolutions for taxpayers involved in IRS investigations and audits.

Prior to joining the firm in 2018, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney, and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California; where, with 27 years as a trial lawyer, she personally litigated over 2,000 tax cases on behalf of the United States.

Ms. Brown obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax Counsel, Vice-Chair of the ABA’s Section of Taxation’s Criminal and Civil Tax Penalties Committee, Co-Chair of the UCLA Tax Controversy Institute, Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference, an ABA Loretta Collins Argrett Fellowship Mentor, and is a frequent lecturer and author on tax controversy topics, including international compliance and criminal tax matters. Ms. Brown has been recognized as one of California’s top 100 leading women lawyers, the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award, Chambers High Net Worth in Tax and Tax Fraud, and an honoree of the inaugural Lawdragon 500 Leading Global Tax Lawyers.

For more information, please contact Sandra R. Brown at brown@taxlitigator.com

Robert S. Horwitz is a Principal of Hochman Salkin Toscher Perez P.C. and has over 40 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year. He was previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section.

Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board.

Mr. Horwitz was previously a trial attorney, US Department of Justice Tax Division and an Assistant United States Attorney, Tax Division, Los Angeles. He was the 2022 recipient of the Joanne M. Garvey Award for lifetime achievement in and outstanding contributions to the field of tax law and the 2021 recipient of the Orange County Bar Association, Tax Chair Recognition award.

For more information, please contact Robert S. Horwitz at horwitz@taxlitigator.com

Sebastian Voth is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax investigations, litigation and appeals, and complex tax matters. Prior to entering private practice, Mr. Voth served for 15 years at the Internal Revenue Service including most recently as a Special Trial Attorney with the IRS Office of Chief Counsel’s Strategic Litigation Division leading trial teams in all phases of litigation before the Tax Court. During his tenure with the IRS, Mr. Voth served on the leadership team of the nationwide IRS Counsel mentoring program and mentored numerous IRS attorneys. He is the recipient of two Lucite Awards for significant Tax Court opinions and received a 2024 Special Act Award (Strategic Litigation), the 2023 Nationwide Innovator of the Year (LB&I), the 2022 Nationwide Special Trial Attorney of the Year (SB/SE), the 2017 U.S. Department of the Treasury Outstanding Litigator and the 2017 Nationwide Attorney of the Year (SB/SE). Serving as a Special Trial Attorney, Mr. Voth handled some of the IRS’s most significant and complex litigation matters.

For more information, please contact Sebastian Voth at voth@taxlitigator.com

Philipp Behrendt is an Associate at Hochman Salkin Toscher Perez P.C., licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Philipp is a Liaison to the Young Lawyer Committee for the ABA Tax Section’s Civil and Criminal Tax Penalties Committee and served on the Beverly Hills Bar Association’s Barristers Board of Governors from 2022 to 2023. Philipp is the Chair of the Beverly Hills Bar Association’s Tax Section, a Liaison.

For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.

We are pleased to announce that Michel R. Stein will be speaking at the upcoming UT Law 73rd Annual Taxation Conference on You Can’t Always Get What You Want . . . But You Can Try Sometimes: The Latest Tax Court Jurisdictional Disputes and Other Rolling Topics being held at the AT&T Conference Center, Austin, Texas, Thursday, December 4, 2025, 2:30 p.m. – 3:30 p.m. (PST).

Tax Court litigation continues to evolve. Discuss challenges created by recent developments including the effect of Jarkesy v. SEC on penalty assessments and the National Taxpayer Advocate’s recent recommendations to subject assessable penalties to the deficiency procedures and to extend the Court’s jurisdiction to refund cases.

Click Here for More Information

Michel R. Stein, a principal of Hochman Salkin Toscher Perez P.C., is a nationally recognized tax attorney with nearly 30 years of experience in tax controversy and planning for individuals and business entities. He is widely respected for his ability to resolve complex and sensitive tax controversies before the Internal Revenue Service and the California Franchise Tax Board, including matters involving significant civil and criminal exposure, and is a trusted resource to clients and advisors navigating the most challenging areas of federal and state tax law. His commentary and insights have been featured in leading tax publications, webinars, and media outlets addressing emerging issues in tax enforcement and policy.

Mr. Stein has represented hundreds of clients in civil tax examinations, administrative appeals, and litigation before the U.S. Tax Court, U.S. District Courts, California Superior Court, and the U.S. Courts of Appeals. He routinely advises and defends clients in matters involving California Residency, Digital Assets and Cryptocurrency Investigations, High-Net-Worth Taxpayer Compliance and Examination, Domestic and International Tax Compliance, Voluntary Disclosures and Streamlined Filings, Challenges to Listed and Reportable Transactions, Partnership Tax and Audit Rules, Employment Tax and Worker Classification Issues, as well as tax controversies arising from Complex Real Estate and Business Transactions.  

Mr. Stein began his legal career as an Attorney Advisor to Special Trial Judge Larry Nameroff of the U.S. Tax Court and is a Certified Specialist in Taxation Law by the State Bar of California.

For more information, please contact Michel R. Stein at stein@taxlitigator.com.