TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Michel R. Stein along with Bryan C. Skarlatos (Kostelanetz LLP) and G. Michelle Ferreira (Greenberg Traurig) will be speaking at the upcoming NYU 84th Institute on Federal Taxation on The Role of the Tax Advisor in the Tax System: Ethical and Penalty Standards for Advising Clients being held at the Fairmont Hotel, San Francisco, Thursday, November 20, 2025, 5:15 p.m. – 6:55 p.m. (PST).

This presentation analyzes the functions and roles of transactional tax lawyers and tax advisors when advising clients and providing a degree of insurance, or penalty protection, to their clients. How sure do advisors have to be before they can tell a client that it is okay to take a deduction or defer or report income as capital gain, etc.? What should an advisor be thinking about as they approach difficult tax questions for their clients? This panel addresses the role of tax advisors in the tax system and uses real-world hypotheticals to illustrate issues that tax advisors must consider when providing tax advice. 

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Michel R. Stein is a principal of Hochman Salkin Toscher Perez P.C. who 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.  

For more information, please contact Michel R. Stein at stein@taxlitigator.com.