TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Edward M. Robbins, Jr., Jonathan Kalinski, and Philipp Behrendt will also be speaking on June 24th at the 2026 Annual Tax Controversy Seminar, Problem Solving Day & BBQ at the Bergen Community College at the Meadowlands. BBQ to follow at The Green at Hackensack Court Square on the following topics:

Edward M. Robbins, Jr.
International Tax Controversies: Challenges & Strategies

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Jonathan Kalinski
Criminal Exposure

Philipp Behrendt
Tax Controversy & Audit Triggers

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Edward M. Robbins, Jr. has been a Principal with the law firm of Hochman Salkin Toscher Perez P.C. since 2004. Mr. Robbins represents clients in civil and criminal tax litigation and in tax disputes and controversies before the Internal Revenue Service and in federal and state court matters. Before entering private practice, Mr. Robbins was an Assistant United States Attorney with the Central District of California, Tax Division. Mr. Robbins left the government after ten years serving as the Chief of the Tax Division, six years as Assistant Division Chief, nine years as Assistant United States Attorney, and 4 years as a District Counsel attorney with the IRS Chief Counsel office in Los Angeles. Mr. Robbins has an LLM in Taxation from the University of San Diego. He is a Certified Specialist in Tax Law for the State Bar of California, Board of Legal Specialization, and a fellow of the American College of Tax Counsel (ACTC). Mr. Robbins has served as an Adjunct Professor at both Golden Gate University School of Law and Loyola Law School.

For more information, please contact Edward Robbins, Jr. at EdR@taxlitigator.com

Jonathan Kalinski is a Principal of the law firm of Hochman Salkin Toscher Perez P.C. whose practice focuses on litigating 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. Jonathan also handles all California tax controversies including FTB, EDD, and CDTFA.

Mr. Kalinski 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

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 Robert S. Horwitz will be speaking at the upcoming BHBA webinar on The Unitary Business Theory and New Limits on Taxing Nonresident Sole Proprietors on Monday, June 22, 2026, 4:30 p.m. (PST).

The Franchise Tax Board has pushed hard to tax nonresidents on amounts the FTB claims is California source income, often arguing their sole proprietorships qualify as unitary businesses subject to apportionment. On May 1, 2026, the California Court of Appeal rejected that theory in Garcia-Rojas v. Franchise Tax Board, holding that a single person engaged in one business activity cannot operate a unitary business. The decision dismantles the reasoning behind the OTA’s ruling in Appeal of Bindley and narrows the reach of the unitary business doctrine. Robert breaks down the court’s analysis, what it means for nonresident taxpayers, how it may support claims for refund and be used as a defense to claims a nonresident owes California income tax.

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Robert Horwitz a Principal of Hochman Salkin Toscher Perez P.C. 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. He is the 2022 recipient of the California Lawyers Association Joanne M. Garvey Award for lifetime achievement and outstanding contributions to the field of tax law.

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

We are pleased to announce that four of our Principals will be speaking at the upcoming 18th Annual NYU Tax Controversy Forum, June 25-26, 2026, at the Westin New York Time Square, on the following key topics:

MICHEL R. STEIN
Challenging Civil Tax Penalties and Interest Reasonable Cause, 7508A, and More
June 25th at 4:30 p.m. (EST)

SANDRA R. BROWN
A Practical Guide and Best Practices for Tax Refund Litigation
June 25th at 4:30 p.m. (EST)

JONATHAN KALINSKI
A Guide to Understanding BBA Audits and Appeals
June 25th at 2:10 p.m (EST)

PHILIPP BEHRENDT
Clients, Cryptocurrency, and Controversies -Hear from the Experts
June 26th at 1:30 p.m (EST)

For 18 years, the NYU School of Professional Studies Tax Controversy Forum has brought together government representatives and expert private practitioners to share their perspectives on a variety of topics involving federal tax audits, appeals, and litigation. The forum covers a wide range of controversy work, from procedural seminars to substantive programs, international issues, ethical problems, current enforcement initiatives, sensitive audits, and civil and criminal tax penalties.

It will be a great program. The link for registration and finding out more about this event is below. 

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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.

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

Jonathan Kalinski is a Principal of the law firm of Hochman Salkin Toscher Perez P.C. whose practice focuses on litigating 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. Jonathan also handles all California tax controversies including FTB, EDD, and CDTFA.

Mr. Kalinski 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

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.

Joseph Garza is a Dallas attorney who allegedly helped clients evade taxes on more than $1 billion of income through a circular flow of funds between the clients and shell service corporations that purported to provide services to the clients’ businesses and shell investment corporations. He was initially charged by the United States with eighteen counts of wire fraud, in violation of 18 U.S.C. §1343, one count of conspiracy to commit wire fraud, in violation of 18 U.S.C. §1349, twenty-four counts of aiding and abetting the filing of false and fraudulent tax returns, in violation of 26 U.S.C. §7602(2), and one count of conspiracy to defraud the United States in violation of 18 U.S.C. §371. A superseding indictment added three CPA as co-defendants. United States v. Joseph Garza, Criminal No. 3:22-CR-0390-S (N.D. Tex).

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Robert Horwitz a Principal of Hochman Salkin Toscher Perez P.C. 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. He is the 2022 recipient of the California Lawyers Association Joanne M. Garvey Award for lifetime achievement and outstanding contributions to the field of tax law.

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

We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Melissa Briggs will be speaking at the upcoming CPAacademy webinar on Tax Relief Under Section 7508A(D) Penalties, Interest & Claims on Thursday, June 18, 2026, 2:00 p.m. – 3:00 p.m. (PST).

This program examines the potential impact of Internal Revenue Code §7508A(d), a disaster relief provision that may have suspended certain federal tax deadlines during the COVID-19 national emergency period. The presentation will review the statutory framework of §7508A, analyze the decisions in Abdo v. Commissioner and Kwong v. United States, and discuss whether taxpayers may have viable claims for the refund or abatement of penalties and interest. Participants will learn the practical steps for preserving and pursuing these claims, including the use of protective refund claims, and will explore California’s conformity to the federal rules. Special attention will be given to the significance of the July 10, 2026 deadline and the opportunities and risks facing taxpayers and practitioners. 

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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

Robert Horwitz a Principal of Hochman Salkin Toscher Perez P.C. 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. He is the 2022 recipient of the California Lawyers Association Joanne M. Garvey Award for lifetime achievement and outstanding contributions to the field of tax law.

For more information, please contact Robert Horwitz at horwitz@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-three 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.

We are pleased to announce that Dennis Perez, Michel R. Stein, and Robert S. Horwitz will be speaking at the upcoming CalCPA webinar on Navigating Federal and State Tax Residency Issues: IRS Examination Guidance, State Regulations, and Remote Workers on Tuesday, June 16, 2026, 9:00 a.m. – 10:30 a.m. (PST).

This webinar will guide tax professionals and advisers on the latest IRS residency examination guidance and California residency issues. The panel will discuss federal and state tax residency rules, California residency issues, income allocation issues in the residency context, managing residency audits, and best practices for advising clients who are considering leaving California. California state tax residency rules, and an increase in residency audits and enforcement, require tax professionals to know state residency and income allocation issues, so they can properly advise their clients when these issues arise.

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Dennis Perez has extensive experience in the representation of clients in civil and criminal tax litigation and in tax disputes and controversies before the Internal Revenue Service and all the California taxing agencies. Mr. Perez was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in Los Angeles, California. Mr. Perez 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. Mr. Perez was the 2025 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. 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. Mr. Perez 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

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

Robert Horwitz a Principal of Hochman Salkin Toscher Perez P.C. 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. He is the 2022 recipient of the California Lawyers Association Joanne M. Garvey Award for lifetime achievement and outstanding contributions to the field of tax law.

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

The 2015 Balanced Budget Act (BBA) instituted a new partnership audit regime under which, like the Tax Equity and Fiscal Responsibility Act (TEFRA) partnership audit regime, the IRS conducts audits of partnerships at the partnership level but, unlike the TEFRA audit regime, imposes liability on the partnership rather than directly on the partners. The BBA partnership audit regime applies to returns filed for tax years beginning on and after January 1, 2018. The IRS issued complex regulations under the BBA partnership regime. Last July, the Tax Court issued an opinion invalidating one of the regulations regarding the time for issuing a Notice of Final Partnership Adjustment (FPA) after a partnership makes a modification request. J. M. Assets v. Commissioner, 165 T.C. No. 1 (2025). 

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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. Additional information is available at http://www.taxlitigator.com

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

Hot off the press is the Tax Court’s decision in Paschall v. Commissioner, T.C. Memo. 2026-46, which is the first significant merits decision addressing whether proof-of-stake rewards are taxable when received. The Court held that Alvie and Patricia Paschall had unreported income from Cardano staking rewards credited to Mr. Paschall’s eToro account in 2021.

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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

The California Office of Tax Appeals (OTA) recently published two precedential sales tax pending decisions that, in practical terms, answered questions regarding personal liability, penalties, and interest abatements for unpaid sales tax. Part I focused on the Appeal of Sundown Entertainment Group, Inc., 2026-OTA-225P. There, the OTA sustained a large sales tax determination after the normal three-year statute of limitations had expired, holding that the CDTFA established fraud, properly imposed the 40 percent penalty for knowingly failing to remit collected sales tax reimbursement, and did not abuse its discretion in denying further interest abatement.

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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

We are pleased to announce that Steven Toscher, Robert S. Horwitz, and Cory Stigile will be speaking at the upcoming Barbri webinar on CDTFA Sales and Use Tax Examinations: High-Risk S&U Tax Issues, California S&U Tax Audits, Preparing for CDTFA Scrutiny on Tuesday, June 9, 2026, 10:00 a.m. – 11:50 a.m. (PST).

This webinar will provide businesses and their tax advisers with a practical framework for preparing clients for California Department of Tax and Fee Administration (CDTFA) examinations and defending positions taken on California sales and use (S&U) tax returns. Our panel of knowledgeable tax attorneys will outline current areas of focus and recent legislative and administrative developments in California related to S&U tax.

We are also pleased to announce that we will be able to offer a limited number of complimentary registrations for this program on a first come first serve basis. If you are interested in attending, please contact Sharon Tanaka at sht@taxlitigator.com.

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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.

Robert Horwitz a Principal of Hochman Salkin Toscher Perez P.C. 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. He is the 2022 recipient of the California Lawyers Association Joanne M. Garvey Award for lifetime achievement and outstanding contributions to the field of tax law.

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