TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that two of our Principals will be speaking at the upcoming ABA Tax Section 2026 May Tax Meeting, May 7-9, 2026, at the Marriott Marquis Washington, D.C., on the following key topics:

On the Front Lines: Criminal Tax Enforcement Priorities, Investigations, and Prosecutions: May 9^th at 9:30 a.m (EST)

Sandra R. Brown, along with Ben Tompkins, Nardiello, Turanchik, Tompkins LLP, Justin Campbell, IRS CI, Senior Executive for Strategy and Innovation, and former acting Deputy Chief, IRS CI, Jay Nanavati, Kostelanetz LLP, and Anshuman Vaidya, Hinshaw & Culbertson LLP, will examine the current state of federal criminal tax enforcement. Panelists will address the latest priorities and strategic direction of the IRS Criminal Investigation Division, including shifts in investigative focus and resource allocation under new leadership. The discussion will cover IRS criminal tax priorities, significant recent tax prosecutions and their practice implications, coordination between IRS Criminal Investigation and the Criminal Tax Section attorneys who are now under newly created Department of Justice National Fraud Enforcement Division, and the evolving landscape of cryptocurrency and digital asset-related criminal tax enforcement. Panelists will also discuss practical defense strategies for practitioners representing clients facing criminal tax exposure in this environment.

Due Process at 250: Penalties, Parallel Proceedings, and Constitutional Limits – Part I: May 8^th at 4:35 pm (EST)

Melissa Briggs, along with Julie Ciamporcero Avetta, The Tax Law Center at NYU Law, John Colvin, Colvin + Hallett, Lauren Darwit, Moore Tax Law Group; Carolyn A. Schenck, Caplin & Drysdale, and Michael A. Villa, Jr., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, will provide a lively discussion regarding how constitutional arguments are playing an increasingly prominent role in tax litigation. As America marks its 250th birthday, this timely session will explore how Fifth Amendment and due process claims are raised and addressed in parallel civil and criminal matters, summons enforcement disputes, and other pre-assessment and trial-stage proceedings. Panelists will examine how courts evaluate requests for stays in the face of parallel investigations, the consequences of asserting the Fifth Amendment in civil tax cases, and the jurisdictional and evidentiary issues raised by constitutional defenses, with particular focus on how the Tax Court and district courts manage these issues, allocate burdens, and ensure procedural fairness.

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Sandra R. Brown is a Principal of Hochman Salkin Toscher Perez P.C., where her practice focuses on criminal tax investigations, grand jury matters, litigation, and sentencing matters as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals and litigation. Ms. Brown’s extensive experience and successes have included many notable cases including two U.S. Supreme Court decisions, numerous 9^th Circuit rulings and numerous favorable administrative resolutions for taxpayers involved in IRS investigations and audits.

Prior to joining the firm in 2018, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney, and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California; where, with 27 years as a trial lawyer, she personally litigated over 2,000 tax cases on behalf of the United States.

Ms. Brown obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax Counsel, Vice-Chair of the ABA’s Section of Taxation’s Criminal and Civil Tax Penalties Committee, Co-Chair of the UCLA Tax Controversy Institute, Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference, an ABA Loretta Collins Argrett Fellowship Mentor, and is a frequent lecturer and author on tax controversy topics, including international compliance and criminal tax matters. Ms. Brown has been recognized as one of California’s top 100 leading women lawyers, the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award, Chambers High Net Worth in Tax and Tax Fraud, and an honoree of the inaugural Lawdragon 500 Leading Global Tax Lawyers.

For more information, please contact Sandra R. Brown at brown@taxlitigator.com

Melissa Briggs is a principal of Hochman Salkin Toscher Perez P.C. where she represents clients in civil and criminal tax controversies. Ms. Briggs has over twenty-three years of litigation experience in private, nonprofit, and government practice. Ms. Briggs spent over nine years as an appellate attorney for the U.S. Department of Justice, Tax Division, Appellate Section. She served almost seven years as an Assistant United States Attorney with the United States Attorney’s Office for the Central District of California’s Tax Division. She began her legal career as a law clerk to the Hon. Phyllis A. Kravitch on the United States Court of Appeals for the Eleventh Circuit. 

Ms. Briggs is a fellow of the American College of Tax Counsel; American Bar Association, Tax Section Loretta Collins Argrett Fellowship Mentor; vice-chair of the California Lawyer’s Association Tax Section, Tax Practice and Procedure Committee, and active member of the Women Lawyers Association of Los Angeles.   

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