TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Michel R. Stein along with Thomas Giordano-Liscari (Greenberg Glusker) will be speaking at the upcoming Barbri webinar on IRS Audits of Expatriates: Section 965 Transition Tax, Exit Tax, Non-Filers, and the Examination Process, Wednesday, December 10, 2025, 10:00 a.m. – 11:30 a.m. (PST).

This webinar will provide tax professionals and advisers with an in-depth discussion of the IRS examination of taxpayers living abroad. The panel will focus on Section 965 transition tax, exit tax, and critical issues for non-filers; guide tax practitioners through the examination process; and explain best practices to withstand the ongoing scrutiny of these taxpayers’ returns.

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 R. Stein at stein@taxlitigator.com.