TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Sandra R. Brown and Philipp Behrendt will be speaking at the upcoming 11th Annual USD School of Law – RJS Law Tax Institute being held at the Joan B. Kroc Institute for Peace & Justice, Theatre on Friday, July 17, 2026, on the following topics:

Sandra R. Brown
Criminal Panel: “Criminal Tax Workshop“
4:00 p.m. – 5:30 p.m. (PST)

Philipp Behrendt
Cryptocurrency “Pitfalls, Planning, and Opportunities”
1:45 p.m. – 2:45 p.m. (PST)

The Institute is the premier annual tax event in San Diego. The region’s top tax attorneys, enrolled agents (EAs), certified public accountants (CPAs), law and business school professors will discuss topics including government loan relief and abuses, challenges in cross-border transactions, and practical and realistic solutions in trust, estate planning, in addition to the Criminal Tax Workshop and Cryptocurrency Panel.

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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 Brown at brown@taxlitigator.com.

Philipp Behrendt is a Principal 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.