We are pleased to announce the 37th Annual National Institute on Criminal Tax Fraud and the 10th Annual National Institute on Tax Controversy is going virtual and will be held on February 24-26th, 2021. As usual, we anticipate a line-up of all-star government and private practice practitioners discussing the cutting edge issues in civil and criminal tax enforcement. More to come.

The 37th Annual National Institute on Criminal Tax Fraud and the 10th Annual National Institute on Tax Controversy is the yearly gathering of the criminal tax controversy and criminal tax defense bar. This program brings together high-level government representatives, judges, corporate counsel, and private practitioners engaged in all aspects of tax controversy, tax litigation, and criminal tax prosecutions and defense. Please join us.

Click Here for More Information.

Bankruptcy ruins your credit score but comes with the promise of a clean slate, reducing or even wiping out debts including tax assessments.  However, to earn a discharge one has to reveal all assets and income, and the temptation to hide assets often proves too great for less scrupulous debtors.  Obtaining a discharge while secretly retaining substantial assets seems like a no-lose proposition.  Unless, that is, you get caught.  However, the consequences of getting caught for committing bankruptcy fraud historically haven’t been as bad as one might think, as often the most serious punishment was simply a denial of discharge of indebtedness.  The IRS’s trumpeting of relatively lengthy sentences such as the 18-month sentences below belies the truth, namely that such sentences are rare because bankruptcy fraud prosecutions are rare.

One of us (Evan) was the Bankruptcy Fraud Coordinator in the Los Angeles U.S. Attorney’s Office for a number of years, and was disappointed that bankruptcy crimes were so low on the FBI’s priority list that only a few investigations were approved each year in a judicial district whose 18-million-plus population is as large as New York State’s (the fourth most-populous state).  Given that IRS Criminal Investigations also did not work many bankruptcy cases, despite the existence of a specialized Bankruptcy Fraud Unit, this meant that bankruptcy crimes by and large went uncharged.  This enforcement gap frustrated just about everyone involved with the bankruptcy system, including judges and the Office of the United States Trustee, an arm of the Department of Justice charged with protecting the integrity of the system.  The US Trustee has personnel assigned to refer cases for investigation and to support any bankruptcy investigation and prosecution, which is a severely underutilized resource given how few bankruptcy fraud investigations take place. 

Because debtors typically owe taxes along with other debts, the IRS is often among the hardest-hit victims of bankruptcy fraud.  With so many tax crimes to prosecute and so few resources, this has not historically been an area of focus, however, for its Criminal Investigation division. 

Current IRS Commissioner Chuck Rettig has prioritized enforcement since taking office in late 2018, and one of his important reforms was to create a “Fraud Enforcement Office” in March 2020 to develop civil cases for referral to Criminal Investigations and to identify audits involving less severe conduct that should remain as civil fraud matters.  When the head of the Fraud Enforcement Office identifies focus areas, it’s a signal to IRS civil agents to look for viable criminal cases amongst their inventory, and to criminal defense counsel to expect more of that type of case in a year or two. 

Last week, Damon Rowe, head of the Fraud Enforcement Office, announced “Operation Liquidation,” which he said would focus on taxpayers who commit bankruptcy fraud as a means of cheating on their taxes.  He used an example familiar to those of us who have prosecuted or defended bankruptcy fraud cases – someone who transfers assets to a nominee shortly before filing bankruptcy with an unwritten agreement that the nominee would hold the assets until after discharge and then return them to the debtor.  If the debtor has a tax debt, this run-of-the-mill bankruptcy fraud (18 U.S.C. Section 152, concealment of assets) is two frauds in one, as it also is an attempted  evasion of payment of tax (26 U.S.C. Section 7201) at the same time. 

Commissioner Rettig has been beating the drum for more evasion-of-payment referrals from Revenue Officers and focusing on bankruptcy cases is a smart move.  Further, bankruptcy cases frequently offer something that standard Revenue Officer referrals do not: judicial findings that the debtor/taxpayer has committed fraud.  Where a judge has already found fraud and the debtor owes substantial tax debts, turning that case into a criminal investigation or civil fraud examination is almost a no-brainer.  Damon Rowe is a former Special Agent who just moved over from Criminal Investigation, meaning he knows which levers to pull on the criminal side including contacting Bankruptcy Fraud Coordinators with whom he no doubt interacted during his decades as a Special Agent.  Those who really pay attention will also note that the IRS refreshed the “Criminal Investigation Strategies” section of its bible, the Internal Revenue Manual, in August 2020 to further underscore that agents should be looking for criminal tax fraud within bankruptcy.  https://www.irs.gov/irm/part9/irm_09-005-003#idm139666666427792

As with all such operations, the real question is whether the IRS will devote its scarce civil and criminal fraud resources to these investigations.  We suspect that the IRS will decide that selecting from among cases where a judge has already found fraud and where the US Trustee is willing to assist, is akin to fishing with dynamite and they will soon have more good cases than they know what to do with.  This focus, added to the IRS’s increased use of data mining to select cases, cryptocurrency training for special agents, and increased enforcement resources under this Commissioner, means the IRS hopes to see a substantial uptick in the number and quality of criminal investigations from the low point a few years ago. 

Of course, whenever the IRS publicizes an increased focus and enhanced presence in any area of enforcement, it is not only the taxpayers who are put on notice; practitioners (in this case, bankruptcy lawyers) are also put on alert.  This serves the IRS’s continual goals of increasing compliance and providing practitioners with a point of contact for a client who may have an interest in reporting allegations of fraud in any particular area of interest to the IRS.

Like any federal crime, bankruptcy fraud, even more so if charged along with tax evasion, carries significant penalties, most notably a sentence of incarceration and an order of restitution, of which the later the IRS can hold a taxpayer accountable for up to 40 years. 

Perhaps merely being denied a discharge won’t continue to be the worst consequence that befalls taxpayers who try to use a bankruptcy filing to evade payment of taxes.              

EVAN J. DAVIS – For more information please contact Evan Davis – davis@taxlitigator.com or 310.281.3288. Mr. Davis has been a principal at Hochman Salkin Toscher Perez P.C. since November 2016.  He spent 11 years as an AUSA in the Office of the U.S. Attorney (C.D. Cal), spending three years in the Tax Division where he handed civil and criminal tax cases and eight years in the Major Frauds Section of the Criminal Division where he handled white-collar, tax, and other fraud cases through jury trial and appeal.  As an AUSA, he served as the Bankruptcy Fraud coordinator, Financial Institution Fraud coordinator, and Securities Fraud coordinator.  Among other awards as a prosecutor, he received an award from the CDCA Bankruptcy Judges for combatting Bankruptcy Fraud and the U.S. Attorney General awarded him the Distinguished Service Award for his work on the $16 Billion RMBS settlement with Bank of America.  Before becoming an AUSA, Mr. Davis was a civil trial attorney in the Department of Justice’s Tax Division in Washington, D.C. for nearly 8 years, the last three of which he was recognized with Outstanding Attorney awards. 

Mr. Davis represents individuals and closely held entities in federal and state criminal tax (including foreign-account and cryptocurrency) investigations and prosecutions, civil tax controversy and litigation, sensitive issue or complex civil tax examinations and administrative tax appeals, and white-collar criminal investigations including campaign finance, FARA, money laundering, and health care fraud. 

SANDRA R. BROWN – Ms. Brown has been a principal at Hochman Salkin Toscher Perez P.C. since March 2018.  Prior to joining the firm, Ms. Brown spent more than 26 years as a federal trial attorney, including serving as the Acting United States Attorney, the First Assistant United States Attorney, and the Chief of the Tax Division of the Office of the U.S. Attorney (C.D. Cal).  Ms. Brown’s broad range of experience in complex civil tax controversies and criminal tax investigations and litigation includes having handled over 2,000 cases on behalf of the United States before the United States District Court, the Ninth Circuit Court of Appeals, the United States Bankruptcy Appellate Panel, and the California Superior Court.  In addition to other honors, commendations, and awards, Ms. Brown has received the Internal Revenue Service Criminal Investigation Chief’s Award and the IRS’s Mitchell Rogovin National Outstanding Support of the Office of Chief Counsel Award, respectively, the two most prestigious criminal and civil awards available for presentation by the IRS to a Department of Justice employee.Ms. Brown represents individuals and entities on a national and local level in complex federal criminal investigations and litigation as well as sensitive civil tax controversy examinations and litigation matters.  Ms. Brown obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax Counsel, co-chair of the NYU Tax Controversy Section, and a member of the Women’s White Collar Defense Association.  Ms. Brown may be reached at brown@taxlitigator.com or 310.281.3217.


Posted by: Robert Horwitz | November 23, 2020

Saved by Beard—Taxpayer’s Return Was Timely, by Robert S. Horwitz

I don’t mean the Seinfeld episode “The Beard” or the San Francisco Giants’ former closer, Brian “The Beard” Wilson.  I mean the Beard test for determining whether information provided the IRS constitutes a tax return.  Fowler v. Commissioner, 155 T.C. No. 7 (Sept. 9, 2020), involved the question of whether a Form 1040 electronically filed by the petitioner was a return and whether it was properly filed.  The facts in the case are simple:

Petitioner had been a victim of identity theft in 2013 and the IRS had sent him a Identity Protection (IP) PIN prior to October 15, 2014, the date his CPA transmitted the 2013 return.  Petitioner authorized his CPA to e-file the return and the CPA e-signed the return with his Practitioner PIN and electronically filed it with the IRS.  The CPA received a Submission ID from the IRS, acknowledging that the return had been received.  He then received notice that the return was rejected because it did not have an IP PIN.  A 2013 return with petitioner’s IP PIN was not transmitted to the IRS until April 30, 2015, and the return was processed by the IRS.  But for the inclusion of the IP PIN the April 30, 2015, return was identical to the October 15, 2014, return. 

After an audit, the IRS issued a Statutory Notice of Deficiency (SNOD) to the taxpayer on April 8, 2018.  He filed a petition with the Tax Court, claiming that the SNOD was barred by the three-year statute of limitations on assessment.  The petitioner and the IRS filed cross motions for summary adjudication on the issue of whether the SNOD was time barred.  The Tax Court granted petitioner’s motion.

Whether the SNOD was time barred turned on two questions: first, was the October 15, 2014 submission a required return and second, was it properly filed.  The Tax Court noted that Code defines return as “the return required to be filed by the taxpayer” and neither the Code nor the regulations expand on this definition.  Thus, in Beard v. Commissioner, 82 T.C. 766 (1984), aff’d 793 F.2d 129 (6th Cir. 1986), the Tax Court established a three-part test to determine whether something is a return:

  1. Does the document purport to be a return and does it provide sufficient information to calculate the tax liability.
  2. Did the taxpayer make an honest and reasonable effort to satisfy the requirements of the tax laws.
  3. Did the taxpayer sign the return under penalties of perjury.

The Tax Court found it was clear the October 15, 2014, submission met the first prong.  To meet the second prong, the return must appear reasonable on its face; thus, a fraudulent return can satisfy this requirement, although a return having zeros on every line would not.  The earlier submission was identical but for the IP PIN accepted by the IRS and thus it met the second prong. 

The third prong, whether the return was validly signed, was the bone of contention.  The IRS argued that to be a valid signature a return must include the IP PIN.  The Tax Court noted that there was nothing in the regulations requiring an IP PIN.  Treasury. Reg. sec. 1.6695-1(b)(2) requires signing return preparers to electronically sign returns in the manner provided in forms and instructions.  There was no IRS guidance characterizing an IP PIN as a signature.  The instructions to the 2013 Form 1040 just state that the return must be signed with either a Self-Select PIN or a Practitioner PIN.  Petitioner’s CPA used the Practitioner PIN.  The Tax Court stated: “Just as taxpayers must comply with instructions referenced on IRS forms … the IRS cannot disavow the 2013 1040 instructions to accommodate its litigation stance.”  The taxpayer justifiably relied on IRS instructions and the October 15, 2014 submission was signed as required.

The Tax Court rejected the IRS’ argument that Internal Revenue Manual 10.5.3.2.15(3) required an IP PIN for a return to be valid.  That IRM provision states that an electronic return that is filed with a missing IP PIN will be rejected.  This, however, did not mean that petitioner’s submission struck out with the third Beard prong, since a return can be rejected for a number of reasons that do not affect its validity.  Thus, petitioner’s October 15, 2014, submission was a valid return.

The Tax Court then addressed the second issue, whether the return was properly filed.  The test is whether a taxpayer’s “mode of filing” complies with the IRS’s prescribed filing requirements.  A return is filed when it is delivered to the correct IRS office even if it is not accepted by the IRS or not processed.  Here the October 15, 2014 return was properly e-filed, even though it was rejected.  As a result, the SNOD was barred by the statute of limitations.

Associate Justice Oliver Wendell Holmes, Jr., wrote in Rock Island C.R.R. v. United States, 254 U.S. 141, 143 (1920) that “Men must turn square corners when they deal with the Government.”  It is good to see the IRS being required to cut a square corner when dealing with taxpayers. Contact

Robert S. Horwitz at horwitz@taxlitigator.com or 310.281.3200.   Mr. Horwitz is a principal at Hochman Salkin Toscher Perez P.C., former Chair of the Taxation Section, California Lawyers’ Association, a Fellow of the American College of Tax Counsel, a former Assistant United States Attorney and a former Trial Attorney, United States Department of Justice Tax Division.  He represents clients throughout the United States and elsewhere involving federal and state administrative civil tax disputes and tax litigation as well as defending criminal tax investigations and prosecutions. Additional information is available at http://www.taxlitigator.com.

IRS attempts to help cannabis industry taxpayers understand their tax obligations likely signal an increased interest in enforcement, according to practitioners.

Jonathan Kalinski of Hochman Salkin Toscher Perez PC told Tax Notes that the information in the FAQ is well known to the state-legal marijuana industry, but “’the IRS doesn’t just pop up — even though this is brief — a Q&A just for the heck of it.'”

To read full article Click Here.

Posted by: Taxlitigator | October 1, 2020

UCLA 36th Annual Tax Controversy Institute – October 20, 2020

Please join Sandra R. Brown, former Acting United States Attorney, as she moderates a panel featuring IRS Director of Fraud Enforcement Damon Rowe and IRS CI Special Agent in Charge Ryan Korner, entitled “What Every Practitioner Needs to Know to Protect Their Clients and Themselves From Civil Fraud Penalties and Criminal Investigations”, to be webcast on October 20, 2020 at 2:15-3:30 PM (PST). Also joining the panel are Nathan Hochman, former Assistant Attorney General, DOJ Tax Division and Evan Davis, former DOJ Tax Division trial attorney and Assistant United States Attorney, CDCA. This “can’t miss” panel is part of UCLA’s 36th Annual Tax Controversy Institute which annually brings together leading tax practitioners and government officials to discuss current topics in areas of civil and criminal tax controversy.  

Other “can’t miss” panels include:

  • Employment Tax Enforcement- How AB 5 Has Changed the Employment Tax World.
  • Handling the Case of the High Income Non-Filer—What to do….What to do?
  • Handling Your Tax Court Matter in the COVID-19 Environment
  • The Tax Problems Caused by COVID-19 and the Best Practices to Handle Them
  • “Handling the Cannabis Tax Examination—What is Different and What is Not”
  • LB&I’s New High Wealth Examinations-Is there Really Gold in Them Hills

For more information Click Here.

Law360 — Included in Justice Ruth Bader Ginsburg’s monumental legacy are several tax opinions in which she addressed whether a California corporate
franchise tax violates the U.S. Constitution, how states can tax citizens and when employment taxes apply to baseball players’ back pay.

Justice Ruth Bader Ginsburg in a panel discussion at Georgetown University Law Center last October, part of a lecture series named for her. She appeared with former President Bill Clinton and former Secretary of State
Hillary Clinton.

For Full Article Click Here.

Posted by: Taxlitigator | September 15, 2020

UCLA 36th Annual Tax Controversy Institute – October 20, 2020

The 36th Annual UCLA Extension Tax Controversy Institute is right around the corner on October 20th. This year the Institute will be virtual and we have an all star line up of Government representatives and private practitioners who will discuss the cutting edge issues in tax controversy.

We are pleased to announce that Commissioner of Internal Revenue Charles P. Rettig will be giving a luncheon keynote on the state of the IRS.
Join us for an interview with the new Chief of the IRS Criminal Investigation Division Jim Lee and attend panel discussions with SBSE Deputy Commissioners De Lon Harris and Darren Guillot on the current state of examination and collection enforcement.

We will also have panels on the anticipated High Wealth examinations and the IRS approach to non-filers. We will conclude the day with an in-depth discussion of the IRS new Office of Fraud Investigations, including its new Director Damon Rowe and the Special Agent in Charge of the Los Angeles Field Office of the Criminal Investigation Division, Ryan Korner

Please join us. Click Here for more information.

Posted by: sbbrown64 | August 28, 2020

SANDRA BROWN Quoted in in LAW360 on IRS New Fraud Office

The novel coronavirus pandemic isn’t delaying the rampup of the Internal Revenue Service’s recently launched office to combat tax fraud, the office’s director told Law360 in a recent interview.

The former head of the IRS criminal investigation unit is now the director of its new fraud enforcement office. (AP)

Though the pandemic has affected the way the IRS’ Office of Fraud Enforcement communicates, it won’t delay setting up the unit, said Damon Rowe, a former senior official in the IRS’ Criminal Investigation Division. The office plans to have a team of 42 fraud enforcement advisers — revenue agents and officers — hired and on board nationwide in 30 to 45 days, said Rowe, who was tapped to head the fraud office in March.

For Full Article Click Here.

In Badgley v. U.S, 957 F.3d 969 (9th Cir. 2020), the 9th Circuit addressed the unfortunate fact pattern when a taxpayer dies prior to the termination of a lengthy (15-year) grantor-retained annuity trust (“GRAT”).

As background, GRATs allow a grantor to transfer property to a beneficiary in trust while retaining the right to an annuity for a specified term of years.  In the year of the transfer, the grantor is taxed on a gift for the difference between the transferred property and the value of the annuity retained, as computed under the regulations.  At the end of the term, the GRAT dissolves and the property is transferred to the beneficiaries.  Id. at 972. This transfer can be free of estate tax, and with a gift tax that is diminished or even eliminated. Id.  This works to effectively transfer any appreciation of the underlying property in the GRAT if the assets sufficiently appreciate.  This estate and gift planning approach can be attractive at times, such as now, when the interest rates are very low, thereby permitting lower annuity payments, or when assets are either depressed or may significantly appreciate in the future.  The grantor, however, risks that either the property does not appreciate, or that the grantor dies.  Here, the grantor died and the executor of her estate sought to not be taxable on a retained interest.

The 9th Circuit reviewed the District Court’s holding that a decedent’s retained annuity interest from the GRAT both retained a right to income from and permitted continued enjoyment of the property.  Id. at 974.   The 9th Circuit reviewed the lower court decision de novo and held that the government correctly included the entire date-of-death value of the GRAT in the decedent’s gross estate.   Id. at 972.

The Court addressed the taxpayer’s primary argument that the annuity flowing from the GRAT operated as a substitute for a will to relinquish possession and enjoyment of the property, thereby avoiding the force of § 2036(a).  To relinquish the property, the grantor must “absolutely, unequivocally, and without possible reservations, part[ ] with all of his title and all of his possession and all of his enjoyment of the transferred property … [and the transfer] must be unaffected by whether the grantor lives or dies.” Commissioner v. Church’s Estate, 335 U.S. 632 at 645–46.  Accordingly, § 2036(a)(1) focuses on both the grantor, who must completely divest herself of possession, enjoyment, and income, and the beneficiaries, whose interest must “take effect” prior to the grantor’s death. See id. at 637.

Ultimately, the decedent’s annuity was a substantial present economic benefit, requiring inclusion of the GRATs date-of-death value in her estate.  The Court noted that the partnership interest was the only property in the GRAT, and the annuity stemmed from that property interest.  Since decedent died before the termination of the GRAT, the property was not transferred to its beneficiaries before her death thus it remained tied to her by the string she created.  Id. at 973.  Query whether the result may have been different if the asset was transferred for an arms-length note that constituted bona fide indebtedness.  Various other arguments, such as the formula in Treasury Regulation §20.2036-1(c)(2) to calculate the portion of property includable under §2036(a), were rejected by the Court.

While GRATs present potential estate planning benefits (particularly in light of the low §7520 interest rate), the benefits and consequences under the Internal Revenue Code provisions and related regulations hinge on the value of the assets put in trust, the value of the retained annuity interests, and the life expectancy.  While it was possible to have a shorter trust, the taxpayer opted for a longer trust period and arguably retained interests in the property.  Ultimately, the decedent’s remaining strings to the property in the GRAT resulted in the property not being transferred to the beneficiaries, thus remaining in her estate.

Cory Stigile – For more information please contact Cory Stigile – stigile@taxlitigator.com  Mr. Stigile is a principal at Hochman Salkin Toscher Perez P.C., a CPA licensed in California, the past-President of the Los Angeles Chapter of CalCPA and a Certified Specialist in Taxation Law by The State Bar of California, Board of Legal Specialization. Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations. Additional information is available at www.taxlitigator.com

Tenzing Tunden is a Tax Associate at Hochman Salkin Toscher Perez P.C. Mr. Tunden recently graduated from the Graduate Tax Program at NYU School of Law and the J.D. Program at UC Davis School of Law. During law school, Mr. Tunden served as an intern at the Franchise Tax Board Legal Division and at the Tax Division of the U.S. Attorney’s Office (N.D. Cal).

Under the People First Initiative, the IRS asserted it would generally not start new examinations, except for situations with short statutes of limitations.  As the relief provisions of the People First Initiative waned after July 15, 2020, the IRS has resumed collection activities in earnest, and presumably will also begin new examinations.  The IRS has been quite vocal on certain examinations areas such as high income non-filers, micro-captives, and conservation easements.  The IRS has also signaled a re-invigorated fraud referral process in these areas.

While these areas of IRS and congressional interest will undoubtedly continue to get attention, the IRS is continuing to build on expertise to conduct examinations of other substantive areas, including Section 41 research credits.  Last November at the California Lawyers Association Taxation Section’s annual meeting, Chief Counsel Michael Desmond described how the IRS has increased enforcement in the research credit space, in response to potentially aggressive positions taken by taxpayers.  In describing these examinations, he noted the complexities in the statute, as well as the need to understand each taxpayers’ business to determine if the credits were appropriate.  These are highly factual examinations.

Similarly, at last November’s CalCPA Committee of Taxation IRS liaison meeting, a group of Small Business/Self Employed and Large Business and International (“LB&I”) managers, and an IRS Counsel attorney, presented on the complexities involved with examining or developing research credits cases.  As the IRS was dedicating resources to the research credit area, at least prior to COVID-19, we can anticipate that these examinations are not going away.  Moreover, as the examinations involve non-traditional tax or accounting questions, and rely on principles of science, engineering, computer science, or other fields, experts will be involved in the examination, including IRS engineers.

In September 2017, the IRS released LB&I Directive I-04-0917-005 (the “Directive”), which provided guidance to LB&I examiners regarding examination of the credit for increasing research activities under Section 41.  This Directive intended to provide an efficient manner of determining qualified research expenses (“QREs”) for LB&I taxpayers that meet certain specific requirements and to more efficiently manage LB&I’s audit resources.  This Directive only applies to LB&I taxpayers who follow U.S. GAAP to prepare their Certified Audited Financial Statements which show as a separate line item on the income statement the amount of the currently expensed ASC 730 Financial Statement R&D. ASC 730 R&D is made up of the research and development costs currently expensed on a taxpayer’s Audited Financial Statements pursuant for U.S. GAAP purposes, and includes certain specified adjustments.  Given the rigor applied in determining these classifications for GAAP purposes, the Directive permitted examiners to accept as sufficient evidence of QREs the ASC 730 Financial Statement R&D for the Credit Year, thus saving significant examination resources and permitting additional certainty for taxpayers.

While the IRS Directive provides clarity for some taxpayers, any additional amounts of QREs claimed by a taxpayer on its Form 6765 for the Credit Year over the ASC 730 Financial Statement R&D amount are subject an examination, if warranted.  While many Revenue Agents have focused on working existing examinations, albeit with an appreciation for extended information document request deadlines, anticipate that new examinations will commence and the IRS will deploy the resources that it has signaled over the last few years, and in particular last fall.

CORY STIGILE – For more information please contact Cory Stigile – stigile@taxlitigator.com  Mr. Stigile is a principal at Hochman Salkin Toscher Perez P.C., a CPA licensed in California, the past-President of the Los Angeles Chapter of CalCPA and a Certified Specialist in Taxation Law by The State Bar of California, Board of Legal Specialization. Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations. Additional information is available at www.taxlitigator.com

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