TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

For many partnerships, § 1402(a)(13) long appeared to offer a relatively straightforward rule: a limited partner’s distributive share of partnership income generally is excluded from self-employment income, while guaranteed payments for services are not. The difficulty has always been that the Code does not define “limited partner,” leaving open how much weight should be given to state-law status and, separately, to the partner’s actual role in the business.

Section 1402(a)(13) excludes from net earnings from self-employment a limited partner’s distributive share of partnership income, while generally leaving guaranteed payments for services subject to self-employment tax. The provision has been essentially unchanged since 1977. What Congress did not do was define “limited partner.”

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Philipp Behrendt is a Principal 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 and the Blockchain and Web3 Law Section.

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

Robert S. 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 clients in criminal tax investigations and prosecutions. In 2022 the Tax Section of the California Lawyers Association awarded him the Joanne M. Garvey Award for lifetime achievement in and contributions to the field of tax law. 

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

Marc Montano is an Associate at Hochman Salkin Toscher Perez P.C. where his focus is on representation of clients in civil and criminal tax litigation and investigations. Mr. Montano joined the firm in 2026 while attending NYU Law School, where he received his LL.M. in Taxation.

Prior to joining the firm, Mr. Montano interned with the IRS Office of Chief Counsel where he worked on matters including a case stemming from one of the largest tax fraud cases in history of over $7 billion in fraudulent tax deductions. His experience at the IRS included successfully arguing a Motion to Dismiss before the U.S. Tax Court, working on tax shelter cases before trial and matters before the IRS Independent Office of Appeals. Mr. Montano also interned with the United States District Court for the Southern District of Indiana, where he gained experience in federal civil and criminal litigation.

For more information, please contact Marc Montano at montano@taxlitigator.com

If you thought federal investigators had moved on from pandemic-era relief fraud, or that the IRS was too bogged down to police shady tax preparers or tax shelter promoters, 2026 is proving otherwise.

Over recent months, a distinct and aggressive pattern has emerged in federal white-collar enforcement when it comes to criminal tax enforcement: IRS Criminal Investigation (IRS-CI) and the Department of Justice (DOJ) Fraud Enforcement Division (Fraud Division) have sharply focused their crosshairs on tax return preparers, tax shelter promoters and employment-based Paycheck Protection Program (PPP) tax fraud.

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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 9th 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.

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. He spent 7.5 years as a DOJ Tax civil litigator and then 11 years as a criminal AUSA in the Office of the U.S. Attorney (C.D. Cal), including 3 years handling civil and criminal tax cases and 8 years as a white-collar prosecutor handling tax and other fraud cases from investigation through jury trial and appeal. As an AUSA, he served as the Bankruptcy Fraud coordinator, Financial Institution Fraud coordinator, and Securities Fraud coordinator. 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 U.S. Supreme Court in 2023.

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

We are pleased to announce that Jonathan Kalinski, Cory Stigile, Melissa Briggs and Sebastian Voth will be speaking at the California Lawyers Association 2026 California All-Tax Conference being held at the Westin San Diego on the following topics:

Jonathan Kalinski
Cannabis Update

Cory Stigile
Recent Developments and Practical Strategies in Representing Clients

Melissa Briggs
Give and Take: Expansion and Contraction of Taxpayers Rights

Sebastian Voth
Economic Substance and Abusive Transactions: Strategies, Pitfalls and Ethics Considerations in Representing Taxpayers 

This conference stands as California’s leading educational and networking event for tax professionals from across the country. Attendees include attorneys, accountants, corporate tax executives, financial planners, enrolled agents, state and federal government officials, and tax practitioners at every level of experience.

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Jonathan Kalinski is a Principal of the law firm of Hochman Salkin Toscher Perez P.C. and specializes in both civil and criminal tax controversies as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets and provides tax advice to taxpayers and their advisors throughout the world. He handles both Federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski is a California Lawyers Association Taxation Section Executive Committee Member and an ABA Loretta Collins Argrett Fellowship Mentor. 

For more information, please contact Jonathan Kalinski at kalinski@taxlitigator.com.

Cory Stigile is a Principal at Hochman Salkin Toscher Perez P.C., who specializes in tax controversies as well as business and international tax. His representation includes federal and state tax controversy matters, including sensitive tax-related examinations and investigations for individuals, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). He has litigated cases in the U.S. Tax Court, the U.S. District Court, the Court of Federal Claims and the 9th Circuit Court of Appeals.

Mr. Stigile is a Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization.

Mr. Stigile is also a CPA licensed in California. He is an active volunteer with CalCPA and the AICPA, and is the President of PADI Foundation. 

For more information, please contact Cory Stigile at stigile@taxlitigator.com.

Melissa Briggs is a Principal of Hochman Salkin Toscher Perez P.C. where she represents clients in civil and criminal tax controversies. Ms. Briggs has over twenty-four years of litigation experience in private, nonprofit, and government practice. Ms. Briggs spent over nine years as an appellate attorney for the U.S. Department of Justice, Tax Division, Appellate Section. She served almost seven years as an Assistant United States Attorney with the United States Attorney’s Office for the Central District of California’s Tax Division. She began her legal career as a law clerk to the Hon. Phyllis A. Kravitch on the United States Court of Appeals for the Eleventh Circuit. 

Ms. Briggs is a fellow of the American College of Tax Counsel; American Bar Association, Tax Section Loretta Collins Argrett Fellowship Mentor; vice-chair of the California Lawyer’s Association Tax Section, Tax Practice and Procedure Committee, and active member of the Women Lawyers Association of Los Angeles.  

For more information, please contact Melissa Briggs at briggs@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

Two years ago, in August 2024, the Tax Court in Varian Medical Systems, Inc. v. Commissioner, 163 T.C. 76 (2024), faced the issue of whether a regulation issued under the provisions of the Tax Cuts & Jobs Act (TCJA) was valid. In that case, the taxpayer claimed a deduction for dividends paid by a foreign subsidiary under Internal Revenue Code sec. 245A for amounts treated as IRC sec. 78 dividends due to a mismatch between the effective date of sec. 245A and that of the TCJA amendments to sec. 78. Applying Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024), the Tax Court invalidated a regulation that gave the amendments to sec. 78 an earlier effective date than TCJA provided, holding that “No matter what the revised regulation intended to interpret, it cannot contradict the clear effective date provided for in the statutory text.”

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Robert S. 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 clients in criminal tax investigations and prosecutions. In 2022 the Tax Section of the California Lawyers Association awarded him the Joanne M. Garvey Award for lifetime achievement in and contributions to the field of tax law. 

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

Prosecutors have nearly unchecked power to decide who to bring charges against and what charges to bring. Grand Juries almost always return a “true bill” when asked by federal prosecutors and 90+ percent of defendants plead guilty when charged with federal tax crimes. Once a defendant signs a plea agreement, there’s little analysis of the charges because the judge, prosecutor, and defense attorney turn their attention to sentencing. That means the defense counsel’s analysis of the law and strength of evidence and advice to plead guilty is often the sole check on prosecutors’ charging overreach. The Tenth Circuit Court of Appeals recently overruled a district court’s denial of a defendant’s attempt to undo her guilty plea after arguing her lawyer failed to inform her that her actions might not be illegal under a bank fraud statute and that the government had to prove she knew her failure to report certain income on her tax returns was illegal.

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Evan J. Davis has been a principal at Hochman Salkin Toscher Perez P.C. since November 2016. He spent 7.5 years as a DOJ Tax civil litigator and then 11 years as a criminal AUSA in the Office of the U.S. Attorney (C.D. Cal), including 3 years handling civil and criminal tax cases and 8 years as a white-collar prosecutor handling tax and other fraud cases from investigation through jury trial and appeal. As an AUSA, he served as the Bankruptcy Fraud coordinator, Financial Institution Fraud coordinator, and Securities Fraud coordinator. 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 U.S. Supreme Court in 2023.

For more information, please contact Evan J. Davis at davis@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 9th 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.

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

For taxpayers with potentially willful tax noncompliance, the IRS Voluntary Disclosure Practice (“VDP”) has always offered a metaphorical “carrot and stick” bargain: come forward before the government finds you, disclose the conduct, pay the tax and some penalties, and in return, substantially reduce the risk of criminal prosecution.

In recent years, however, that bargain has become increasingly difficult to sell. The current VDP can be slow, expensive, and administratively burdensome. That matters because voluntary disclosure works only if taxpayers with genuine criminal exposure see a meaningful advantage to coming forward.

Now, significant changes appear imminent. On August 25, 2026, IRS Criminal Investigation Chief Jarod Koopman announced that the IRS is close to finalizing what he called a “new voluntary disclosure program,” expected to be released within approximately 60 days. 

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Steven Toscher is the Managing Principal of the law firm and 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.

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.  He 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.

Philipp Behrendt is a Principal 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 and the Blockchain and Web3 Law Section.

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

In a rare and welcomed victory for taxpayer rights and administrative fairness, the IRS has agreed to remove the willfulness checkbox from the next version of the Form 14457—the application form for the Voluntary Disclosure Practice (VDP). In addition, the program will make allowances not to preclude income derived from marijuana sales by changing its definition of illegal source income. 

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Steven Toscher is the Managing Principal of the law firm and 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.

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.  He 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.

Philipp Behrendt is a Principal 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 and the Blockchain and Web3 Law Section.

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

Dear Colleague-

The highly anticipated 2026 UCLA Extension Tax Controversy Conference is fast approaching, and this is an event you don’t want to miss! By registering now through the link below, you can gain invaluable insights through our distinguished keynote speakers, Emin Toro, a respected Judge of the United States Tax Court, and Jarod Koopman, Chief Compliance Officer of the IRS, with responsibilities covering both civil and criminal enforcement.

We have an impressive lineup of programs and speakers designed to equip you with essential strategies for navigating complex tax enforcement challenges.

We would like to highlight one of our morning programs which will cover the highly controversial billionaires tax on the November ballot. Whether the proposition passes or not, the proposal has already focused many people on potentially leaving California and that no doubt will draw the interest of the California Franchise Tax Board.

Who Wants to be a Billionaire-Handling California Residency Audits and Contested Matters Before the OTA and the Courts

We have an outstanding group of panelists having extensive experience in handling and litigating California residency disputes, including Dennis Perez of Hochman Salkin Toscher Perez P.C., Andrew Katzenstein, of HCVT and Marty Dakessian of Dakessian Law Ltd.

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Private aircraft have been on the tax authorities’ radar for some time. Now, quite literally, the radar may be doing the auditing.

The Los Angeles Times reported this week that the Los Angeles County Assessor has sent hundreds of tax bills to private aircraft owners, including aircraft linked by a flight-tracking service to some of the country’s best-known celebrities and business figures, for allegedly unpaid county property taxes. According to the report, the county expects its effort to produce approximately $38 million in additional revenue.

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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 9th 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 contact Sandra Brown at brown@taxlitigator.com.

Philipp Behrendt is a Principal 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 and the Blockchain and Web3 Law Section.

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

We are pleased to announce that Melissa Briggs will be speaking on Hot Topics in Tax Litigation at the upcoming Contra Costa County Bar Association webinar being held on Thursday, September 10, 2026, 12:00 p.m. – 1:00 p.m. (PST).

A survey of some of the year’s most significant developments in tax controversy and litigation. Ms. Briggs will present a curated selection of recent decisions and emerging issues shaping practice before the IRS and the courts. Her presentation will focus on notable Tax Court and Circuit court decisions, including the continuing fallout from Loper Bright on the validity of Treasury regulations, as well caselaw developments important to keep in mind in representing clients in collection and filing and litigating claims for refund.

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Melissa Briggs is a Principal of Hochman Salkin Toscher Perez P.C. where she represents clients in civil and criminal tax controversies. Ms. Briggs has over twenty-four years of litigation experience in private, nonprofit, and government practice. Ms. Briggs spent over nine years as an appellate attorney for the U.S. Department of Justice, Tax Division, Appellate Section. She served almost seven years as an Assistant United States Attorney with the United States Attorney’s Office for the Central District of California’s Tax Division. She began her legal career as a law clerk to the Hon. Phyllis A. Kravitch on the United States Court of Appeals for the Eleventh Circuit. 

Ms. Briggs is a fellow of the American College of Tax Counsel; American Bar Association, Tax Section Loretta Collins Argrett Fellowship Mentor; vice-chair of the California Lawyer’s Association Tax Section, Tax Practice and Procedure Committee, and active member of the Women Lawyers Association of Los Angeles.  

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