TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Dennis Perez, Robert S. Horwitz and Sebastian Voth will be speaking at the upcoming CalCPA Tax Talk webinar on Office of Tax Administration: Handling a Case Before California Office of Tax Appeals, Tuesday, December 9, 2025, 9:00 a.m. – 10:30 a.m. (PST).

This webinar will guide tax professionals and advisers on the stages of a California income tax case from preparation for the audit, through protesting an NPA, appealing to the Office of Tax Appeals (OTA), settlement with the FTB, and the trial of a case before the OTA. It will help you learn what you need to know to represent your client effectively with the FTB, what needs to be done to successfully settle a case with FTB’s Settlement Bureau, and representing your client before the OTA, including briefing, discovery and a hearing before a three administrative law judge panel.

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For over thirty-eight (38) years Dennis Perez has been representing clients in civil and criminal tax litigation and tax disputes and controversies before the Internal Revenue Service and all the California taxing agencies. Dennis was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in Los Angeles, California. He 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. 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. Dennis 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.

Robert S. Horwitz is a Principal of Hochman Salkin Toscher Perez P.C. and 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.

Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board.

Mr. Horwitz was previously a trial attorney, US Department of Justice Tax Division and an Assistant United States Attorney, Tax Division, Los Angeles. He was the 2022 recipient of the Joanne M. Garvey Award for lifetime achievement in and outstanding contributions to the field of tax law and the 2021 recipient of the Orange County Bar Association, Tax Chair Recognition award.

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