TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Sebastian Voth’s article, The Shifting Ground of Subchapter K: Economic Substance in Focus, was published in the November 2025 issue of TAXES Magazine. Although the IRS issued guidance this year announcing its intent to withdraw certain basis-shifting regulations and granting penalty relief for failure to disclose related transactions, a key revenue ruling continues to apply the codified economic substance doctrine. The article examines the doctrine’s evolution, including its codification, the current landscape of basis-shifting transactions, insights on tax textualism, and strategic approaches amid ongoing uncertainty.

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Sebastian Voth is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax investigations, litigation and appeals, and complex tax matters. Prior to entering private practice, Mr. Voth served for 15 years at the Internal Revenue Service including most recently as a Special Trial Attorney with the IRS Office of Chief Counsel’s Strategic Litigation Division leading trial teams in all phases of litigation before the Tax Court. During his tenure with the IRS, Mr. Voth served on the leadership team of the nationwide IRS Counsel mentoring program and mentored numerous IRS attorneys. He is the recipient of two Lucite Awards for significant Tax Court opinions and received a 2024 Special Act Award (Strategic Litigation), the 2023 Nationwide Innovator of the Year (LB&I), the 2022 Nationwide Special Trial Attorney of the Year (SB/SE), the 2017 U.S. Department of the Treasury Outstanding Litigator and the 2017 Nationwide Attorney of the Year (SB/SE). Serving as a Special Trial Attorney, Mr. Voth handled some of the IRS’s most significant and complex litigation matters.

For more information, please contact Sebastian Voth at voth@taxlitigator.com

Hochman Salkin Toscher Perez, P.C is very honored that once again the firm along with five (5) of our Principals have been ranked as National and Regional Tiers 1 in Tax Litigation and Controversy by Best Law Firms.

Founded in 1960, Hochman Salkin Toscher Perez P.C., is internationally recognized as the preeminent tax law firm on the West Coast. The reputation of the firm for excellence and integrity in the tax community is unparalleled. The firm specializes in civil and criminal tax litigation, tax controversies and tax disputes with the federal, state, and local taxing authorities, and white-collar criminal defense. We attract the most difficult cases and produce the best results for clients before the Federal Appellate Courts, the Federal District Courts, the Bankruptcy Courts, the United States Tax Court, and various state courts, including the California Franchise Tax Board California Department of Tax and Fee Administration and the California Employment Development Department.

The Best Law Firms rankings are derived from peer-review evaluations, client input, and other measures of legal excellence. According to Best Lawyers, these rankings highlight firms that have demonstrated outstanding performance in specific practice areas.  

Our Principals included in this prestigious recognition are:

Steven Toscher

Steven Toscher is the Managing Principal of the law firm, and specializes in civil and criminal tax controversy and litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization, a Fellow of the American College of Tax Counsel and has received an “AV” rating from Martindale Hubbell. Mr. Toscher serves as Co-Chair of the UCLA Tax Controversy Institute and Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference.  Mr. Toscher is a frequent lecturer and author on tax controversy and litigation topics and is a co-author of the BNA Portfolio, Tax Crimes. Mr. Toscher was the 2018 recipient of the Joanne M. Garvey Award, given annually to recognize lifetime achievement and outstanding contributions to the field of tax law by a senior member of the California tax bar. Mr. Toscher is also the recipient the USD School of Law Richard Carpenter Excellence in Tax Award. In 2024 Mr. Toscher was the  recipient of the prestigious Jules Ritholz Memorial Merit Award presented by the Civil and Criminal Tax Penalties Committee of the Taxation Section of the American Bar Association, recognizing tax lawyers who have demonstrated outstanding dedication, achievement and integrity in the field of civil and criminal tax controversies. For more information, please contact Steven Toscher at toscher@taxlitigator.com.

Dennis Perez

Dennis Perez was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in Los Angeles, California. Mr. Perez is a Certified Tax Specialist, California State Bar Board of Certification and is also a Fellow of the American College of Tax Counsel. He frequently lectures on advanced civil and criminal tax topics at seminars and before national, state and local bar associations and accountancy groups. Mr. Perez is a co-author of the BNA Portfolio, Tax Crimes, served as the Chair of the Los Angeles Lawyer Magazine Editorial Board and is the first recipient of the Los Angeles Lawyer Sam Lipsman Service Award for outstanding service to the Los Angeles Lawyer Magazine. Mr. Perez is the recipient of the 2025 Joanne M. Garvey Award for lifetime achievement in and contribution to the field of tax law by the Taxation Section of the California Lawyers Association. He is past Chair of the Tax Procedure and Litigation Committees of the Taxation Sections of the State Bar of California and the Los Angeles County Bar Association. Mr. Perez is past President of the Alumni Board for the UCLA School of Law and has served as an Adjunct Professor, Golden Gate University, Graduate School of Taxation. For more information, please contact Dennis Perez at perez@taxlitigator.com

Robert S. Horwitz

Robert S. Horwitz a Principal of Hochman Salkin Toscher Perez P.C. represents clients throughout the United States and elsewhere involving federal and state administrative civil tax disputes and tax litigation as well as defending clients in criminal tax investigations and prosecutions. Mr. Horwitz is a former Chair of the Taxation Section, California Lawyers’ Association, a Fellow of the American College of Tax Counsel, a former Assistant United States Attorney and a former Trial Attorney, United States Department of Justice Tax Division. Mr. Horwitz was the 2022 Joanne M. Garvey Award recipient for lifetime achievement in and contribution to the field of tax law by the Taxation Section of the California Lawyers Association.  Mr. Horwitz is an Order of the Coif graduate of Northwestern University Law School.    For more information, contact Robert Horwitz at horwitz@taxlitigator.com.

Edward M. Robbins, Jr.

Edward M. Robbins, Jr. has been a Principal with the law firm since 2004. Mr. Robbins represents clients in civil and criminal tax litigation and in tax disputes and controversies before the Internal Revenue Service and in federal and state court matters. Before entering private practice, Mr. Robbins was an Assistant United States Attorney with the Central District of California, Tax Division. Mr. Robbins left the government after ten years serving as the Chief of the Tax Division, six years as Assistant Division Chief, nine years as Assistant United States Attorney, and 4 years as a District Counsel attorney with the IRS Chief Counsel office in Los Angeles. Mr. Robbins has an LLM in Taxation from the University of San Diego. He is a Certified Specialist in Tax Law for the State Bar of California, Board of Legal Specialization, and a fellow of the American College of Tax Counsel (ACTC). Mr. Robbins has served as an Adjunct Professor at both Golden Gate University School of Law and Loyola Law School. For more information, please contact Edward Robbins, Jr. at EdR@taxlitigator.com.

Avram Salkin

Avram Salkin is a founding member of the firm. He has over fifty (50) years of extensive experience in resolving complex Federal and state tax controversies and disputes, in structuring and negotiating complex transactional matters (including the acquisition and disposition of real estate and businesses), family wealth planning, estate planning and probate. Recognizing a lifetime of achievements and contributions to the field of taxation, Mr. Salkin has been honored with the Dana Latham Award (Los Angeles County Bar Association), the Joane M. Garvey Award (Taxation Section of the State Bar of California), and the Bruce I. Hochman Award (UCLA Tax Institute). Mr. Salkin served as a Member of the Board of Governor’s for the Beverly Hills Bar Association, was Vice-Chair of the Tax Advisory Commission for the California State Bar Board of Legal Specialization, and has served as the Tax Articles Editor for the Los Angeles County Bar Journal. Mr. Salkin holds an “A-V” rating from Martindale-Hubbell. 

We are pleased to announce that Melissa Briggs will be speaking at the upcoming California Lawyers Association Women in Tax Hot Topics in Federal Litigation webinar, Thursday, November 20, 2025, 12:00 p.m. – 1:00 p.m. (PST).

This program will provide the learner with updates regarding cases pending or decided in the Supreme Court, United States Courts of Appeals, United States District Courts, and the United States Tax Court in 2025. The program will provide the learner an understanding the current status of pending litigation, as well as theories underlying litigation trends. Hot topics covered will include Tax Court jurisdiction, right to jury trial in penalty cases, non-assessable penalties, valuation misstatements, employee retention credits and the Administrative Procedures Act, the economic substance doctrine, and transfer pricing.

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

The attorneys of Hochman Salkin Toscher Perez P.C. celebrate with Dennis on his receiving the prestigious Joanne M. Garvey Award at the 2025 Taxation Section Meeting of the California Lawyers Association.

The Joanne M. Garvey Award is presented by the Taxation Section to a member of the California tax bar to recognize lifetime achievement and outstanding contribution in the field of tax law.

Congratulations Dennis. Well deserved.

For over thirty-eight (38) years Dennis has been representing clients in civil and criminal tax litigation and tax disputes and controversies before the Internal Revenue Service and all the California taxing agencies. Dennis was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in Los Angeles, California. He is a Certified Tax Specialist, California State Bar Board of Certification and is also a Fellow of the American College of Tax Counsel. He frequently lectures on advanced civil and criminal tax topics at seminars and before national, state and local bar associations and accountancy groups. He is a co-author of the BNA Portfolio, Tax Crimes, has served as the Chair of the Los Angeles Lawyer Magazine Editorial Board and is the first recipient of the Los Angeles Lawyer Sam Lipsman Service Award for outstanding service to the Los Angeles Lawyer Magazine. He is past Chair of the Tax Procedure and Litigation Committees of the Taxation Sections of the State Bar of California and the Los Angeles County Bar Association. Dennis is past President of the Alumni Board for the UCLA School of Law and has served as an Adjunct Professor, Golden Gate University, Graduate School of Taxation. 

For more information, please contact Dennis Perez at perez@taxlitigator.com.

We are pleased to announce that Cory Stigile along with Chad D. Nardiello (Nardiello, Turanchik, Tompkins), David B. Porter (Law Offices of David B. Porter) and Brian A. Sullivan (Sullivan & Company) will be speaking at the upcoming NYU 84th Institute on Federal Taxation on Current IRS Enforcement Efforts and the Path Ahead being held at the Fairmont Hotel, San Francisco, Sunday, November 16, 2025, 1:15 p.m. (PST).

Overview of current IRS enforcement priorities. defensive strategies and dispute resolution opportunities. The IRS is at a historic crossroads facing significant budget reductions and declining staff levels. Practical “in the tax trenches” advice on current and anticipated future IRS enforcement efforts providing context for the many challenges ahead focusing on various IRS Compliance Campaigns. high-income and high-wealth individuals and their related entities. digital assets. corporations. partnerships, other current IRS priorities.

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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.

We are pleased to announce that Michel R. Stein along with Bryan C. Skarlatos (Kostelanetz LLP) and G. Michelle Ferreira (Greenberg Traurig) will be speaking at the upcoming NYU 84th Institute on Federal Taxation on The Role of the Tax Advisor in the Tax System: Ethical and Penalty Standards for Advising Clients being held at the Fairmont Hotel, San Francisco, Thursday, November 20, 2025, 5:15 p.m. – 6:55 p.m. (PST).

This presentation analyzes the functions and roles of transactional tax lawyers and tax advisors when advising clients and providing a degree of insurance, or penalty protection, to their clients. How sure do advisors have to be before they can tell a client that it is okay to take a deduction or defer or report income as capital gain, etc.? What should an advisor be thinking about as they approach difficult tax questions for their clients? This panel addresses the role of tax advisors in the tax system and uses real-world hypotheticals to illustrate issues that tax advisors must consider when providing tax advice. 

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Michel R. Stein is a principal of Hochman Salkin Toscher Perez P.C. who 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.  

For more information, please contact Michel R. Stein at stein@taxlitigator.com.

We are pleased to announce that Sebastian Voth together with Gary L. Howard, CPA, (Managing Partner of Howard Kittle & Company CPAs) co-authored “A Double Dose: Why Two Kovels Are Better Than One,” published in the November 2025 issue of Orange County Lawyer Magazine. The article provides a strong overview of the Kovel doctrine, explains its practical application in preserving privilege during sensitive tax matters, and uses complex, real-world scenarios to illustrate why, in certain cases, engaging two Kovel accountants with distinct and well-defined roles may better preserve privilege and lead to more effective results.

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Sebastian Voth is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax investigations, litigation and appeals, and complex tax matters. Prior to entering private practice, Mr. Voth served for 15 years at the Internal Revenue Service including most recently as a Special Trial Attorney with the IRS Office of Chief Counsel’s Strategic Litigation Division leading trial teams in all phases of litigation before the Tax Court. During his tenure with the IRS, Mr. Voth served on the leadership team of the nationwide IRS Counsel mentoring program and mentored numerous IRS attorneys. He is the recipient of two Lucite Awards for significant Tax Court opinions and received a 2024 Special Act Award (Strategic Litigation), the 2023 Nationwide Innovator of the Year (LB&I), the 2022 Nationwide Special Trial Attorney of the Year (SB/SE), the 2017 U.S. Department of the Treasury Outstanding Litigator and the 2017 Nationwide Attorney of the Year (SB/SE). Serving as a Special Trial Attorney, Mr. Voth handled some of the IRS’s most significant and complex litigation matters.

For more information, please contact Sebastian Voth at voth@taxlitigator.com

Hochman Salkin Toscher Perez P.C. is proud to be part of the team representing the American College of Tax Counsel as amicus curiae in Shleifer v. United States, No. 25-12719, an appeal in the United States Court of Appeals Eleventh Circuit that raises important questions about the proper scope and application of the substantial variance doctrine in federal tax refund cases. The brief, co-authored by principals Melissa Briggs and Robert Horwitz, as well as the ACTC press release are available here.

Amicus Brief

Press Release

Melissa Briggs is a Principal of the law firm 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.  Ms. Briggs also served as a law clerk to the Honorable Phyllis A. Kravitch on the United States Court of Appeals for the 11th Circuit.

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

Robert S. Horwitz is a Principal of Hochman Salkin Toscher Perez P.C. and 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.

Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board.

Mr. Horwitz was previously a trial attorney, US Department of Justice Tax Division and an Assistant United States Attorney, Tax Division, Los Angeles. He was the 2022 recipient of the Joanne M. Garvey Award for lifetime achievement in and outstanding contributions to the field of tax law and the 2021 recipient of the Orange County Bar Association, Tax Chair Recognition award.

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

We are pleased to announce that five of our principals will be speaking at the upcoming California Lawyer’s Association 2025 Annual Meeting of the Tax Bar and Tax Policy Conference, November 12-14, 2025 at the Westin San Diego Bayview on the following key topics:

Sandra R. Brown
Immigration and Tax: Expatriation, Denaturalization, and Enforcement

Michel Stein
Don’t Be a Jerk: Civility in Tax Practice

Cory Stigile
Avoiding Conflicts and Other Ethical Issues

Sebastian Voth
Nuts and Bolts Bootcamp

Philipp Behrendt
AI and Tax

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Sandra R. Brown is a Principal of the law firm Hochman Salkin Toscher Perez P.C., where she specializes in criminal tax investigations, grand jury matters, litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals, as well as civil litigation. Prior to joining the firm, 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.

During her 27 years as a trial lawyer, she personally handled over 2,000 tax cases on behalf of the United States. During her tenure with the government, Ms. Brown received the Internal Revenue Service Criminal Investigation Chief’s Award and the IRS’s Mitchell Rogovin National Outstanding Support of the Office of Chief Counsel Award, the highest recognitions awarded by the IRS to non-IRS employees. 

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 matters. Ms. Brown has been recognized as one of California’s top 100 leading women lawyers and most recently, the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award and honored at the California Lawyers Association Tax Bar and Tax Policy 2024 Toast to Women in Tax.

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

Michel R. Stein 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. 

A sought-after speaker, Mr. Stein frequently lectures at national and regional conferences, including the UCLA Tax Controversy Institute, USC Tax Institute, NYU Tax Controversy Forum and the Florida Tax Institute, as well as programs for the ABA Tax Section and the California Lawyers Association. 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 Stein at stein@taxlitigator.com

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.

Sebastian Voth is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax investigations, litigation and appeals, and complex tax matters. Prior to entering private practice, Mr. Voth served for 15 years at the Internal Revenue Service including most recently as a Special Trial Attorney with the IRS Office of Chief Counsel’s Strategic Litigation Division leading trial teams in all phases of litigation before the Tax Court. During his tenure with the IRS, Mr. Voth served on the leadership team of the nationwide IRS Counsel mentoring program and mentored numerous IRS attorneys. He is the recipient of two Lucite Awards for significant Tax Court opinions and received a 2024 Special Act Award (Strategic Litigation), the 2023 Nationwide Innovator of the Year (LB&I), the 2022 Nationwide Special Trial Attorney of the Year (SB/SE), the 2017 U.S. Department of the Treasury Outstanding Litigator and the 2017 Nationwide Attorney of the Year (SB/SE). Serving as a Special Trial Attorney, Mr. Voth handled some of the IRS’s most significant and complex litigation matters.

For more information, please contact Sebastian Voth at voth@taxlitigator.com

Philipp Behrendt is an Associate 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, a Liaison.

For more information, please contact Philipp Behrendt at behrendt@taxlitigator.com.

We are pleased to announce that Sandra R. Brown along with Caroline Ciraolo (Kostelanetz LLP) and Sharyn Fisk (California State Polytechnic University Pomona) will be speaking at the upcoming Hawaii Tax Institute on Clemency [Pardons and Commutations] – Navigating the Rules, Managing Client Expectations and Ethical Considerations seminar at the Sheraton Waikiki, Wednesday, November 5, 2025, 1:30 p.m. – 2:30 p.m. (HST).

The likelihood that a client, facing a criminal investigation or dealing with a prior conviction, raises the issue of “Can you get me a pardon?” has increased ten-fold. This session will provide an understanding of the legal, practical, and ethical issues practitioners should be cognizant of when stepping into the waters in advising about this increasingly “hot topic” of interest to many clients. 

Sandra R. Brown, former Acting United States Attorney of the Office of the U.S. Attorney (CDCA), is a Principal of Hochman Salkin Toscher Perez P.C., where she focuses on criminal tax investigations, grand jury matters, litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals, as well as civil litigation. During her more than 34 years as a trial attorney, she has personally handled over 2,000 tax cases, including bench and jury trials, on behalf of taxpayers and the United States.

Sandra has been recognized by Chambers High Net Worth in Tax and Tax Fraud, LawDragon’s 500 Top International Tax Attorneys, California’s Super Lawyers, California’s top 100 leading women lawyers and is the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award as well as the IRS Criminal Investigation Chief’s Award and the IRS’s Mitchell Rogovin National Outstanding Support of the Office of Chief Counsel Award.

Sandra obtained her LL.M. in Taxation from the University of Denver and is a fellow of the American College of Tax Counsel.

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