TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Jonathan Kalinski will be speaking at the upcoming CalCPA webinar on Effectively Managing State Income Tax Examinations, Protests and Appeals Before the FTB on Tuesday, April 21, 2026, 9:00 a.m. – 10:30 p.m. (PST).

Successfully navigating a California income tax controversy requires more than technical knowledge—it demands strategic judgment at every step, from audit through appeal and, where necessary, trial. Understanding how and when to develop the record, engage with the Franchise Tax Board (FTB), and position a case for settlement or litigation can significantly impact the outcome.

This webinar will guide tax professionals and advisers through the key stages of a California income tax case, including audit preparation, protests of Notices of Proposed Assessment (NPAs), appeals to the Office of Tax Appeals (OTA), settlement with the FTB, and trial before the OTA and Superior Court. Participants will learn how to represent clients effectively before the FTB, what is required to pursue a successful resolution through the FTB Settlement Bureau, and how to handle OTA proceedings, including briefing, discovery, and hearings before a three-judge administrative law panel.

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

Jonathan Kalinski is a Principal of the law firm of Hochman Salkin Toscher Perez P.C. whose practice focuses on litigating both civil and criminal tax controversies as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets and provides tax advice to taxpayers and their advisors throughout the world. Jonathan also handles all California tax controversies including FTB, EDD, and CDTFA.

Mr. Kalinski handles both Federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski is a California Lawyers Association Taxation Section Executive Committee Member and an ABA Loretta Collins Argrett Fellowship Mentor. 

For more information, please contact Jonathan Kalinski at kalinski@taxlitigator.com