TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce the July 31, 2026 publication of “Refund Dead Ends: Statute-of-Limitation Considerations,” in the The Tax Adviser. Principals  Cory Stigile, Melissa Briggs, and former law clerk Hunter Keaster provide insight, advice, and practical tips on filing timely claims and suits for refunds. The article explains the importance of carefully-prepared timely-filed refund claims, discusses the administrative appeal process of refund denials, and advises practitioners on litigation considerations to ensure that a client’s refund does not run into a dead end.

Link to the Article

Cory Stigile is a Principal at Hochman Salkin Toscher Perez P.C., who specializes in tax controversies as well as business and international tax. His representation includes federal and state tax controversy matters, including sensitive tax-related examinations and investigations for individuals, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues).

He has litigated cases in the U.S. Tax Court, the U.S. District Court, the Court of Federal Claims and the 9th Circuit Court of Appeals.

Mr. Stigile is a Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization.

Mr. Stigile is also a CPA licensed in California. He is an active volunteer with CalCPA and the AICPA, and is the President of PADI Foundation. 

For more information, please contact Cory Stigile at stigile@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.