We are pleased to announce that Sebastian Voth‘s article, The Strategic Use of FOIA in Your Tax Practice, was published in the Winter 2025 issue of the Journal of Tax Practice & Procedure. The article outlines the statutory framework of the Freedom of Information Act (FOIA) and provides guidance for handling FOIA requests in IRS matters. It explores strategic use of FOIA to access IRS records in tax controversies, navigating exemptions and disclosure limitations, coordinating requests with Tax Court discovery, and weighing the advantages and potential pitfalls of filing a FOIA suit in District Court, including considerations around jurisdiction, delay, and procedural hurdles.
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
TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report 
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