I handle civil and criminal tax controversy administrative practice and litigation, including audit defense, criminal defense, and collection matters. I represent business entities and individuals before federal and state taxing authorities, including the IRS, Department of Justice, United States Attorney’s Office, California State Board of Equalization, California Franchise Tax Board, California Employment Development Department, and California Unemployment Insurance Appeals Board.

I handle civil and criminal tax controversy administrative practice and litigation, including audit defense, criminal defense, and collection matters. I represent business entities and individuals before federal and state taxing authorities, including the IRS, Department of Justice, United States Attorney’s Office, California State Board of Equalization, California Franchise Tax Board, California Employment Development Department, and California Unemployment Insurance Appeals Board.

I prosecuted tax and financial crimes under various statutes and defended appeals, as well as represented the United States in tax controversies before the federal district court, the bankruptcy court, and the California state courts. My criminal trial experience includes four jury trials and one bench trial and a probation revocation evidentiary hearing, in cases ranging from subscribing to false tax returns (26 U.S.C. § 7206(1)) or aiding and assisting in the preparation of false returns (26 U.S.C. § 7206(2)) to conspiracy to defraud the United States with respect to claims (18 U.S.C. § 286) or making false, fictitious, or fraudulent claims against the United States (18 U.S.C. § 287). In numerous other cases, I negotiated pre-indictment plea agreements and handled change of plea and sentencing hearings in all cases to which I was assigned, as well as appeals from convictions and/or sentences and post-conviction proceedings under 28 U.S.C. § 2255 and the writ of error coram nobis. I also defended the United States in tax refund suits, wrongful levy actions, suits to enjoin tax collection, and other suits. My civil trial experience in the district court and bankruptcy court includes at least three jury trials and three bench trials in tax collection suits, actions to enjoin tax collection, and actions to determine tax liabilities, including “responsible” person penalties under I.R.C. § 6672. I have extensive criminal and civil law and motion practice in district court and bankruptcy court. I litigated objections to IRS claims, complaints to determine tax liability, complaints to determine dischargeability of taxes, and other adversary proceedings in bankruptcy court. I also enforced IRS summonses and prosecuted suits to set aside fraudulent transfers, to reduce tax liabilities to judgment, and to foreclose federal tax liens.

I defended the Commissioner of Internal Revenue in U.S Tax Court litigation. I rendered advice to the IRS Collection Division on issues such as lien attachment, lien priority, levies, summonses, redemption, applications for certificates of discharge, and lien releases. I also assisted the U.S. Attorney’s Office in defense of suits with tax implications brought against the government in district courts and state courts. I was also specially appointed to represent the U.S. in certain contested matters involving tax issues before the bankruptcy court in Chapter 7, 11, and 13 cases.