The 2026 UCLA Extension Tax Controversy Conference is almost here, and you won’t want to miss it. Register now through the link below.
Hear valuable insights from our distinguished keynote speakers, Emin Toro, Judge, United States Tax Court and Jarod Koopman, Chief, IRS Criminal Investigation.
We’re looking forward to another excellent program, including a panel on “How to Effectively Handle a Payroll Tax Collection Matter, Including the Exposure of Responsible Persons for Liability under IRC Sections 6672 and 7202.” We have an outstanding panel of specialists, including moderator Michael Dallo (Dallo Law Group), Kari Balboa, (Territory Manager, IRS), Pam Grewal (Andersen) Darren Guillot (Alliant Group), and Lorraine Yu (Deputy Area Counsel, IRS Office of Chier Counsel).
This year’s conference will also feature Taxpayer Advocate Service Problem Solving Day, who will be available to assist taxpayers with unresolved IRS tax problems. Appointments are required and must be scheduled ahead of time. To book an appointment, please reach out Ms. Skud at 702-868-5189 by October 20, 2026 to reserve your spot in advance of this event.
We are pleased to announce that Melissa Briggs along with Michele F.L. Weiss (Holtz Slavett Drabkin & Warner) will be moderating at the upcoming California Lawyers Association webinar, Meet the New Tax Court Judges being held on Tuesday, October 13, 2026, 12:00 p.m. – 1:00 p.m. (PST).
Recently appointed Tax Court Judges will provide practitioners with information about their background, discuss best practices in the Tax Court, and discuss recent trends in Tax Court litigation.
Melissa Briggsis 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 than forty years, Bob Jones University v. United States has stood for the proposition that qualification under § 501(c)(3) requires more than satisfying the literal categories in the statute. In Bob Jones Univ. v. United States, 461 U.S. 574, 585–96 (1983), the Court held that an educational institution that engages in racial discrimination is not a “charity” entitled to tax exempt status under Internal Revenue Code § 501(c)(3) since racial discrimination in education violates a “fundamental public policy.” On September 4, 2026, Treasury and the IRS proposed regulations that would deny § 501(c)(3) status to a private school that uses race, color, or national or ethnic origin in administering virtually any school policy or program. The proposal expressly reaches race-conscious measures adopted for remedial or diversity purposes. Racial Nondiscrimination in Private Schools, 91 Fed. Reg. 56,811 (Sept. 4, 2026) (proposed rule) (REG-119986-25).
Steven Toscheris 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.
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.
The BBA Partnership audit and litigation provisions were enacted in 2015 and became effective for tax years beginning on or after January 1, 2018. Internal Revenue Code (“IRC”) §6321(a) requires the IRS mail three notices to the partnership and the partnership representative:
1. Notice of the initiation of partnership proceedings, which advises the partnership and the partnership representative of the initiation of administrative proceedings at the partnership level of any partnership-related item;
2. Notice of proposed partnership adjustments (“NOPPA”) resulting from the proceedings, which sets out the proposed adjustments, any imputed underpayment the partnership will owe and gives the partnership an opportunity to make a modification request; and
3. Notice of final partnership adjustment (“FPA”), which sets out the final adjustments and any imputed underpayment and provides the partnership with the opportunity to petition the Tax Court, the Court of Federal Claims or a district court and to make any push-out election.
Robert S. Horwitzis 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.
We are pleased to announce that Philipp Behrendt will be speaking on From Pig Butchering to the Tax Return: Deducting Crypto Scam Losses at the upcoming Beverly Hills Bar Association live webinar being held on Tuesday, October 6, 2026, 12:30 p.m. (PST).
A practical look at the tax treatment of losses from pig-butchering schemes, fraudulent crypto platforms, rug pulls, hacks, and other scams, including when those losses may be deductible and the substantiation 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.
We are pleased to announce that Sandra R. Brown, Melissa Briggs, Sebastian Voth and Philipp Behrendt will be speaking at the ABA Tax Section Virtual 2026 Fall Tax Meeting being held on October 5-9, 2026 on the following topics:
Sandra R. Brown The Business of Being a Tax Lawyer FromBuilding Business to Building a Career
You’ve Been Served Parts I and II: Current Developments inCivil Tax Collection Suits
Sebastian Voth When Substance Matters – Economic Substance and Penalty Risk in Tax Controversy Practice
Philipp Behrendt Hot Topics for Closely Held Businesses
This conference connects leading tax attorneys, practitioners, and government officials to review updates in federal, state, and local tax policies, employee benefits, tax controversy, and artificial intelligence in legal practice.
Sandra R. Brownis 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.
Melissa Briggsis 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.
Sebastian Vothis 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.
Philipp Behrendtis 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, a Liaison.
Our great line up of speakers are putting the final touches on their presentations for the 42nd Annual UCLA Extension Tax Controversy Institute being held on October 22, 2026.
We anticipate another great program and feature here the panel on “Hot Issues Confronting Taxpayers and the IRS Examination Division.” We have an outstanding panel of specialists, including moderator Joseph Broyles and panelists Tim Bilotta, Chad Nardiello (Nardiello Turanchik Tompkins), Lavar Taylor (Taylor Nelson Amitrano LLP) and Samantha Kittle (Howard Kittle & Company CPAs).
Registration is open and seats are sure to fill up. For registration information see below.
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.”
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.
Robert S. Horwitzis 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.
Marc Montanois 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.
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.
Sandra R. Brownis 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.
Evan J. Davishas 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.
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 ofTaxpayers 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.
Jonathan Kalinskiis 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.
Cory Stigileis 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.
Melissa Briggsis 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.
Sebastian Vothis 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.
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