TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

Philipp Behrendt was recently quoted in “Crypto Theft, Tax Losses, and Recovery,” by Lee A. Sheppard, published in Tax Notes Federal, Volume 192, on August 10, 2026. The article examines the tax consequences of cryptocurrency theft and fraud, including the challenges victims face in establishing a deductible theft loss, demonstrating a profit motive, and proving that there is no reasonable prospect of recovery. It also discusses the practical difficulties of tracing and recovering stolen digital assets and the consumer-protection implications of proposed crypto legislation.

Discussing the importance of developing the evidentiary record necessary to support a theft-loss claim, Behrendt explained:

“The central difficulty for victims is that the tax system does not simply ask whether the taxpayer was harmed. It asks whether the harm fits a statutory category. The administrative file should be built as if the case will be litigated: chronology, transfer trail, communications, platform screenshots, withdrawal-denial messages, law-enforcement reports, exchange records, wallet addresses, and a short legal analysis of the applicable theft statute.”

The article also addresses the requirement that a taxpayer establishes that there is no reasonable prospect of recovery. On the significance and limitations of blockchain tracing, Behrendt cautioned:

“On one hand, blockchain tracing may show where the funds went and sometimes support law enforcement action. On the other hand, the mere theoretical possibility of tracing does not necessarily create a reasonable prospect of recovery.”

Finally, Behrendt emphasized that victims should act promptly both to maximize potential recovery and to preserve the record supporting the tax treatment of the loss:

“The recovery effort is a crucial stage, but as a practical matter it is very difficult. Victims should move quickly to preserve records, file an IC3 [FBI Internet Crime Complaint Center] complaint, report to banks and exchanges, and, where appropriate, obtain blockchain tracing.”

The article further notes Behrendt’s observations regarding the challenges of matching seized cryptocurrency to individual victims and obtaining restitution when stolen assets have moved through commingled accounts and laundering networks.

Click Here for Link to the Article (Subscription Required)

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 Jonathan Kalinski and Sebastian Voth will be speaking at the upcoming CalCPA webinar on Employment Tax Resolving Federal and State Employment Tax Matters – Worker Classification on Tuesday, August 18, 2026, 9:00 a.m. – 10:30 a.m. (PST).

The IRS is increasing enforcement against taxpayers who fail to comply with withholding and remitting of employment taxes. Noncompliance can cause heavy penalties and interest against taxpayers that could destabilize a company and its operations and expose responsible company officers to personal liability. Tax professionals and advisers must grasp a complete understanding of tax rules and available techniques to avoid or minimize tax assessments and penalties. This webinar will guide tax professionals and advisers on critical issues relating to employment taxes. The panel will discuss essential techniques to avoid penalties and handling IRS audits stemming from employment taxes. The panel will also address worker classification issues and methods to overcome them, the impact of California AB 5, key considerations for state versus federal compliance, the Government use of injunctions and criminal aspects.

Click Here to Register

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

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

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

We are pleased to announce the July 31, 2026 publication of “Refund Dead Ends: Statute-of-Limitation Considerations,” in the The Tax Adviser. Principals  Cory Stigile, Melissa Briggs, and former law clerk Hunter Keaster provide insight, advice, and practical tips on filing timely claims and suits for refunds. The article explains the importance of carefully-prepared timely-filed refund claims, discusses the administrative appeal process of refund denials, and advises practitioners on litigation considerations to ensure that a client’s refund does not run into a dead end.

Link to the Article

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-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.

Dear Colleague-

Registration is now open for the 2026 UCLA Extension Tax Controversy Conference, which will be held this year on October 22, 2026, at the Beverly Hills Hotel. It will be the 42nd Conference and you will not want to miss it. You can register for the conference by clicking on the button below.

In addition to our keynote speakers, Emin Toro, Judge, United States Tax Court and Jarod Koopman, Chief, IRS Criminal Investigation, we have a lineup of great programs and speakers:

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

Hot Issues Confronting Taxpayers and the

IRS Examination Division

How to Effectively Use AI in Your Tax Controversy Practice and Not Get in Trouble Doing It

The Wealthiest Generation- Important Issues in the Enforcement of Estate and Gift Taxation

How to Effectively Handle a Payroll Tax Collection Matter, Including the Exposure of Responsible Persons for Liability under IRC Sections 6672 and 7202

Criminal Tax Panel

Follow Us on LinkedIn

We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Cory Stigile will be speaking at the upcoming Strafford webinar on Effectively Managing State Income Tax Examinations, Protests and Appeals on Tuesday, July 28, 2026, 10:00 a.m. – 11:50 a.m. (PST).

This webinar will provide tax practitioners with a practical roadmap for navigating state income tax examinations, protests, and appeals from initial audit contact through final resolution. Our panel of experienced tax controversy attorneys will draw on real world audit and appeals experience to explain how state tax authorities develop issues, evaluate evidence, and resolve disputes—highlighting California procedures while emphasizing strategies that apply nationwide.

Click Here for More Information

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

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

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

 For more information, please contact Michel 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

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

We are pleased to announce that Dennis Perez, Michel R. Stein, and Robert S. Horwitz will be speaking at the upcoming Strafford webinar on Federal and State Tax Residency Rules: Latest IRS Examination Guidance, and Navigating State Tax Regulations, and Remote Workers on Monday, July 20, 2026, 10:00 a.m. – 11:50 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.

This CLE/CPE webinar will provide tax professionals guidance on key planning considerations for taxpayers. The panel will discuss the importance of both citizenship and residence in determining tax liabilities of individuals, challenges for remote workers, allocating income between jurisdictions, dual residency issues, principal items targeted by regulatory authorities, and other key items.

Click Here for More Information

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.

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

 For more information, please contact Michel 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

We are pleased to announce that Sandra R. Brown and Philipp Behrendt will be speaking at the upcoming 11th Annual USD School of Law – RJS Law Tax Institute being held at the Joan B. Kroc Institute for Peace & Justice, Theatre on Friday, July 17, 2026, on the following topics:

Sandra R. Brown
Criminal Panel: “Criminal Tax Workshop“
4:00 p.m. – 5:30 p.m. (PST)

Philipp Behrendt
Cryptocurrency “Pitfalls, Planning, and Opportunities”
1:45 p.m. – 2:45 p.m. (PST)

The Institute is the premier annual tax event in San Diego. The region’s top tax attorneys, enrolled agents (EAs), certified public accountants (CPAs), law and business school professors will discuss topics including government loan relief and abuses, challenges in cross-border transactions, and practical and realistic solutions in trust, estate planning, in addition to the Criminal Tax Workshop and Cryptocurrency Panel.

Click Here for More Information

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

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

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

For more information, please contact Sandra 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 Steve Toscher, Michel R. Stein, and Philipp Behrendt will be speaking at the upcoming Strafford webinar on 2026 Puerto Rico Tax Act Compliance and Challenges on Tuesday, July 14, 2026, 10:00 a.m. – 11:30 a.m. (PST).

This course will provide persons who have taken advantage of Puerto Rico Act 60 and their tax advisors with guidance on managing an IRS examination. The panel will also discuss the favorable treatment for Puerto Rico-source income and areas of likely scrutiny that will inform the IRS audit initiative. The webinar will also detail residency requirements, address modifications made under Puerto Rico Act 38-2026, and outline potential caveats to U.S. taxpayers considering relocation to Puerto Rico for tax purposes.

Click Here for More Information

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.

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

 For more information, please contact Michel 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 1959 opinion, the U.S. Supreme Court held that an out-of-state business whose sole contact with a state was to have “drummers” go into the state to solicit orders could be taxed by that state on income from those sales. In response, Congress enacted Pub. Law 86-272 to limit the power of states to impose a net income tax on out-of-state sellers who have limited business activities within the state. To fall within P.L. 86-272’s protection, an out-of-state seller’s in-state business activity must generally be limited to the “solicitation of orders” for the sale of tangible goods, provided that the orders are sent to a location outside the taxing state for approval and the orders are filled by shipment or delivery from a location outside the taxing state. Pub. Law 86-272 is codified at 15 U.S.C. §§ 381-384.

Click Here for Full Article

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

Let us take a moment to wish our great country happy birthday and recognize that our greatness was not born out of comfort but of severe challenges. 

Thomas Paine wrote in the darkest days of the Revolution,

“Let it be told to the future world, that in the depth of winter, when nothing but hope and virtue could survive…”

“We have it in our power to begin the world over again.”

We are that future world. Two hundred and fifty years later, we enjoy not only the freedoms won by that generation but also shoulder the responsibility to preserve them. 

Let’s celebrate our independence with gratitude, humility, and renewed commitment to the ideals that have carried our nation through its greatest challenges. 

HAPPY FOURTH OF JULY!