We are pleased to announce that four of our attorneys will be speaking at the upcoming ABA Tax Section 2026 Midyear Tax Meeting, January 15-17, 2026 at the Marriott Marquis San Diego Marina on the following key topics:
Michel R. Stein, along with Jeff Oliver, Plante Moran, Rob Kovacev, Miller & Chevalier, and Alexandra Minkovich, Baker McKenzie will speak on What’s Up? Recent Developments and Pending Legislation on Tax Controversy Matters. Join us for a timely review of key cases, IRS rulings and legislation and pending legislation involving tax procedure, penalties, and litigation.
Evan J. Davis, along with Alexander Reid, BakerHostetler, Karen Kelly, Kostelanetz LLP and Joe Rillotta, Meadows Collier, will speak on Exploring the Ins and Outs of a Criminal Tax Investigation and the Particular Risks that Tax-Exempt Organizations Face. Join us for a lively discussion of best practices for responding to and navigating a criminal tax investigation, the potential triggers of such an investigation, and the particular risks that tax-exempt organizations face with the IRS’s increased scrutiny of such clients.
Sebastian Voth, along with Professor Del Wright, Louisiana State University, Jennifer Schinke, Inland Counties Legal Services, and Hon. Emin Toro, United State Tax Court will speak on Anatomy of a Tax Motivated Transaction: Legal and Ethical Perspectives. This panel will provide a critical examination of today’s tax landscape, from highly engineered financial shelters designed for corporations and wealthy individuals to schemes targeting small businesses and low-income taxpayers.
Philipp Behrendt, along with Maria Critelli, Mayer Brown LLP, Rami Khoury, Taylor Nelson Amitrano LLP and Travis Thompson, Fennemore will speak on AI in Tax Controversy. This panel will discuss the ways in which AI is and will continue to impact tax controversy as well as ethical strategies for using AI in tax practice.
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. He 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.
Evan Davis has been a Principal at Hochman Salkin Toscher Perez P.C. since November 2016. 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 US Supreme Court in 2023.
Before joining the firm in 2016, Evan spent nearly 20 years with the US Department of Justice. He was first a civil trial attorney with DOJ’s Tax Division, then an Assistant U.S. Attorney in the C.D. Cal’s Tax Division handling civil and criminal tax cases and, finally, a criminal AUSA in the USAO’s Major Frauds Section handling white-collar, tax, and other fraud cases through jury trial and appeal. He served as the Bankruptcy Fraud coordinator, Financial Institution Fraud Coordinator, and Securities Fraud coordinator. His awards include the U.S. Attorney General’s Distinguished Service Award for Evan’s work on the $16 Billion RMBS settlement with Bank of America. He is also a Fellow of the American College of Trial Counsel.
For more information, please contact Evan Davis at davis@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
Philipp Behrendt is an Associate 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.
For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.
TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report 
Leave a comment