TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Melissa Briggs will be speaking at the upcoming Spidell webinar on Using IRC §7508A to Reduce Your Client’s Liability for Covid-Era Interest & Penalties on Thursday, March 26, 2026, 10:00 a.m. – 12:00 p.m. (PST).

Please join us to:

• Understand how Internal Revenue Code Section 7508A works.
• Appreciate differences between Section 7508A as in effect during the Covid-19 pandemic and the current version of Section 7508A
• Learn what acts are disregarded by a federally declared disaster under Section 7508A
• Know how interest and penalties are affected by Section 7508A
• Understand the latest filing deadline cases, including Abdo v. Commissioner (Tax Court) and Kwong v. United States (Court of Federal Claims)
• Learn how to seek interest or penalty abatement under Section 7508A
• Know California’s conformity to Section 7508A

Click Here to Register

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

Robert Horwitz a Principal of Hochman Salkin Toscher Perez P.C. 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. He is the 2022 recipient of the California Lawyers Association Joanne M. Garvey Award for lifetime achievement and outstanding contributions to the field of tax law.

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

Melissa Briggs is a Principal of the law firm of Hochman Salkin Perez P.C. where she represents clients in civil and criminal tax litigation as well as tax investigations. She has over twenty years of litigation experience, including over 16 years combined experience as an Assistant United States Attorney for the Central District of California, Tax Division, and an Appellate Attorney in the United States Department of Justice, Tax Division, Appellate Section.  

For more information, please contact Melissa Briggs at briggs@taxlitigator.com.