TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Michel R. Stein will be speaking at the upcoming UT Law 73rd Annual Taxation Conference on You Can’t Always Get What You Want . . . But You Can Try Sometimes: The Latest Tax Court Jurisdictional Disputes and Other Rolling Topics being held at the AT&T Conference Center, Austin, Texas, Thursday, December 4, 2025, 2:30 p.m. – 3:30 p.m. (PST).

Tax Court litigation continues to evolve. Discuss challenges created by recent developments including the effect of Jarkesy v. SEC on penalty assessments and the National Taxpayer Advocate’s recent recommendations to subject assessable penalties to the deficiency procedures and to extend the Court’s jurisdiction to refund cases.

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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.  

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 R. Stein at stein@taxlitigator.com.