Charles P. Rettig
E-Mail Address: rettig@taxlitigator.com
Telephone: (310) 281-3200
Facsimile: (310) 859-5104
Chuck Rettig specializes in tax controversies as well as tax, business, charitable and estate planning, and family wealth transfers. His representation includes Federal and state civil and criminal tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. Chuck is a frequent lecturer before national, state and local professional organizations and has authored articles in many national, state and local publications.
Chuck Rettig has been quoted with respect to tax-related matters by the Wall Street Journal, Forbes, Tax Analysts-Tax Notes, the BNA Daily Tax Report, the Los Angeles Times, and other national periodicals. As stated in the Chambers USA Guide, "According to peers, Charles Rettig of small tax controversy boutique Hochman Salkin Rettig Toscher & Perez is phenomenal, just phenomenal.' He has a tremendous reputation' for his work ..." ... "Fantastic controversy tax lawyer" ... "knowledgeable and very intelligent."..."a force to be reckoned with." Further, "Charles Rettig of California's Hochman Salkin Rettig Toscher & Perez is regarded by market sources as a 'brilliant and gifted lawyer'" who "enjoys a superb reputation and benefits from great presence ." As to the firm Chambers USA states "This renowned tax boutique is a go-to firm for tax controversy, particularly for criminal tax cases."
Professional Honors:
2009 Tax Person of the Year (Top 10), Tax Notes/Tax Analysts
Presidents Award for Outstanding Contributions to CPAs in Hawaii, Hawaii Society of CPAs, 2003 - 2004
Top 50 IRS Representation Practitioners for 2008, CPA Magazine (www.cpamagazine.com), 2008.
V. Judson Klein Award for Outstanding Achievement in Taxation, Taxation Section, State Bar of California, 2003
Conference Speaker of the Year Award, California CPA Education Foundation, 2000
Instructor of the Year Award, Graduate Tax Program, Golden Gate University, 2002
UCLA Extension Award for Extraordinary Efforts as Chair of the Annual Tax Controversy Institute to Enhancing Partnerships in the Tax Community for Continuing Education and Professional Development, 2005
Commencement Speaker, Graduate Tax Program, Golden Gate University, 2003
District Directors Award, IRS Los Angeles District, 1998
Keynote Conference Speaker, Hawaii Society of CPAs 42nd Annual Conference, 2002
Top 100 Super Lawyers (Los Angeles County), Los Angeles Magazine / Southern California Super Lawyers Magazine, 2005.
Top Tax Super Lawyers (Los Angeles County), Los Angeles Magazine / Southern California Super Lawyers Magazine, 2004-2010, inclusive.
The Best Lawyers in America, 2004-present
Strathmores Whos Who, Lifetime Member
Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization
Certified Specialist, Estate Planning, Trust & Probate Law, The State Bar of California, Board of Legal Specialization
Martindale-Hubbell AV Preeminent Rating (Highest possible rating)
Professional Activities and Memberships:
IRS Advisory Council (IRSAC)
Chair, 2010-2011
Vice-Chair, 2009 - 2010
Member (SBSE Subgroup), 2008-present
California Franchise Tax Board, Advisory Board, 1998 - present
California State Board of Equalization, Advisory Council 2011 - present
American College of Tax Counsel
Chair, Nominating Committee, 2012 - prseent
Elected Regent, 2009-present
Elected Fellow, 2000 - present
New York University School of Law, Graduate Tax Program, National Board of Advisors, 1999-present
New York University School of Law, Weinfield Associate
New York University School of Law, Wallace-Lyon Associate
New York University Institute on Federal Taxation, Advisory Board, 2008-present
Chair, Tax Controversies Session, 2007-present
Planning Commitee Member, 2007-present
Institute Co-Chair, 2009
UCLA Extension Annual Tax Controversy Institute -
Institute Chair and Planning Committee Member, 1998 -
present
USC Institute on Federal Taxation, Planning Committee
Member, 2003 - present
Executive Committee Member and Subcommittee Chair -
Ethics, Compliance and Enforcement, 2004 - present
AICPA Annual Conference on Tax Planning, Compliance & Controversy, Co-Chair, 2013.
AICPA Annual Conference on Tax Controversy, Co-Chair, 2012.
ABA National Institute on Criminal Tax Fraud, Co-Chair 2011- present
ABA National Institute on Criminal Tax Fraud, Co-Chair, 2010
Wolters Kluwer Law & Business (CCH), Legal Tax Advisory Board, Chair, 2012-present.
NYU 4th Annual Tax Controversy Forum, Co-Chair and Planning Committee Member, 2012
NYU 1st, 2nd, and 3rd Annual Tax Controversy Forum, Co-Chair and Planning Committee Member, 2009-2011
California CPA Education Foundation Board of Trustees, 2007 -2011
American Bar Association, Taxation Section
Council Director, 2012 - present
Civil and Criminal Tax Penalties Committee
Chair, 2009 - 2011
Vice-Chair, 2007 - 2009
Chair, Subcommittee on Civil Penalties, 2002 - 2008
Standards of Tax Practice Committee
Liaison, IRS National Taxpayer Advocate, 2003- 2007
Court Procedure and Practice Committee, Member
Committee on Appointments to the U.S. Tax Court, 2006-2008; 2011-2013
State Bar of California -
Chair, Taxation Section Executive Committee, 1999 - 2000
Chair-Elect, Taxation Section Executive Committee, 1998
-1999
Vice-Chair and Member, Taxation Section Executive Committee, 1995 - 1997
Advisor, Taxation Section Executive Committee, 2002 - present
Immediate Past-Chair, Taxation Section Executive Committee, 2000 - 2001
Chair, Committee of Past-Chairs, 2001-2002
Chair, State and Local Tax Committee, 1998
Estate and Gift Tax Committee, Member
Tax Procedure and Litigation Committee, Member
Beverly Hills Bar Association -
Chair, Taxation Section, 2001 - 2003
Vice-Chair, Taxation Section, 2000 - 2001
Executive Committee Member, Taxation Section, 2003 - present
Chair, Tax Procedure Committee, 2000 - 2001
Chair, State and Local Tax Committee, 1997 - 1999
Los Angeles County Bar Association
Chair, Tax Procedure and Litigation Committee - 1997
State and Local Tax Committee
Society of Trust and Estate Practitioners (STEP), 2009 - present
American Tax Policy Institute, Life Member
CCH Journal of Tax Practice and Procedure, Advisory Board
1999 - present
CCH Journal of Tax Practice and Procedure Tax Practice, Co-Columnist
The Tax Controversy & Litigation Report, Tax Notes, Regular Columnist
IRS Watch - Tax Practice & Procedure, Forbes Blog
http://blogs.forbes.com/irswatch
United States Tax Court Judicial Conference, Invited
Participant, 1999, 2005, 2007, 2009
Golden Gate University, Graduate School of Taxation, Advisory Board, 2006-present
Chapman University School of Law, Graduate Tax Program, Advisory Board, 2004-2008
Association of Tax Counsel, 1997-present
U.S. Court of Federal Claims Bar Association
Federal Bar Association (Taxation Section)
San Fernando Valley Bar Association (Taxation Section)
State Bar of Arizona (Taxation Section)
State Bar of Hawaii (Taxation Committee)
Association of Federal Defense Attorneys
California CPA Education Foundation, Faculty of Lecturers, 1997 - present
California CPA Education Foundation Tax Update and Planning Conference
Conference Co-Chair, 2001,2002; 2006, 2007
Planning Committee, 1999 - present
California CPA Education Foundation Tax and Financial Planning for High Net Worth
Individuals Conference -Planning Committee, 2000
California CPA Education Foundation Family Law Conference - Planning Committee, 1999 - 2000
California CPA Education Foundation International Conference - 2004
California CPA Education Foundation Financial Statements and Tax Fraud Conference
Conference Chair, 2001,2002
Planning Committee, 2001 - present
CSCPA, Committee on Taxation, Los Angeles Chapter,1998 - present
CSCPA, Associate Member, 1998 - present
Committee on Taxation
Litigation Committee (Family Law Section, 2001)
Hawai'i Society of Certified Public Accountants (HSCPA) - Taxation Committee
California Society of Enrolled Agents, Professional Affiliate, 2006-present
Coordinator, IRS Problem Solving Day - Pro Bono Program, LA District, 1998 - 2001
Eagles Lodge West Conference, Taxation Section, State Bar of California
(Co-Chair, Franchise Tax Board Issues,1998-1999), 2001
Los Angeles World Affairs Council
Town Hall Los Angeles, Executive Member
Greater Los Angeles Zoo Association
Honolulu Zoo Association
Santa Barbara Zoo Association
The Academy of Magical Arts, Associate Member
PADI Foundation, a California Non-Profit Public Benefit Corporation, President/Chair, 1991 - present
Crespi Carmelite High School, Encino, CA, Member, Board of Directors 2006-2010
UDT-SEAL Association (udtseal.org), Member 2010-present
Wounded Warrior Project, Advance Guard 2011-present
Professional Affiliations (Speaker / Panelist):
28th Annual Tax Controversy Institute, UCLA Extension, 1998 - present
54th Annual Institute on Federal Taxation, USC Law School, 2003, 2005, 2009
AICPA Conference on Tax Strategies for High Income Taxpayers - 2007-present
AICPA National Conference, 2009-present
35th Annual AICPA National Tax Forum 2009-2011
35th Annual Tax Conference Federal Bar Association, 2011
15th Hemispheric Congress, Anti-Money Laundering and Combating Terrorist Financing (AML/CFT), Panama City, Panama, 2011
6th Annual ACAMS Anti Money-Laundering & Counter-Terriorism Financing Conference,
Amsterdam, The Netherlands, 2010
16th Annual International AML Conference,Miami, FL - 2011
45th Annual Heckerling Institute on Estate Planning, University of Miami, 2011
45th Annual Southern Federal Tax Conference, Atlanta, GA 2010
46th Annual Southern Federal Tax Conference, Atlanta, GA 2011
58th Annual Taxation Conference, Univeristy of Texas, Autin, TX 2010-2011
Georgia Tax Forum, Atlanta, GA, 2010-2011
CCH User Conference, Orlando, FL, 2010
27th Annual ABA National Institute on Criminal Tax Fraud, 2010
28th Annual ABA National Institute on Criminal Tax Fraud and 1st Annual Institute on Civil Tax Controversy, 2011
29th ABA National Institute on Criminal Tax Fraud and 2nd Annual Institute on Civil Tax Controversy, 2012
ABA International Tax Enforcement Conference, 2012
70th Institute on Federal Taxation, Chair, Tax Controversies, 2011
69th Institute on Federal Taxation, Chair, Tax Controversies, 2010
68th Institute on Federal Taxation, NYU, Institue Co-Chair and Chair, Tax Controversies, 2009
67th Institute on Federal Taxation, Chair, Tax Controversies, 2008
66th Institute on Federal Taxation, Chair, Tax Controversies, 2007
IRS Tax Forums 2011 (Las Vegas and Atlanta)
IRS Tax Forums 2010 (Las Vegas and Atlanta)
IRS Tax Forums, 2009 (Las Vegas, San Diego, Atlanta and Orlando)
ASA International Advanced Business Valuation Conference, 2009
Southwest Tax Conference, Nevada Society of CPAs, 2009-2011
Pacific Tax Institute, WSCPA, Seattle, WA 2012
Portland Estate Planning Council Seminar (Portland, OR), 2009
Florida State Bar Taxation Section Annual Conference, 2009, 2010
Western Conference on Tax Exempt Organizations, 2009
Chaminade University Tax Foundation, Annuall Hawaii Tax Institute, 2003-2009
Chaminade University Tax Foundation, Non-Profit Organizations Conference, 2007-2008, 2011
Tax & Tech Update, 2007-2010
Business Valuation TeleConference, Subsequent Events, BV Resources, 2009, 2010
Business Valuation Conference, University of San Diego, 2008
Annual Estate Planning & Taxation Conference, State of the Arts Seminars, 2007
Spidell Estates and Trusts Seminar, 2007
CSEA Super Seminars - 2007
Federal Bureau of Investigation, Corporate Fraud Conference, 2002
ALI-ABA Representing Estate and Trust Beneficiaries and Fiduciaries, 2008
Internal Continuing Education Sessions:
IRS Estate & Gift Tax Attorney CPE Conference, 2011
IRS Compliance Division - Practitioner Representation, 2007
IRS Fraud Technical Advisor Group, 2006
IRS Compliance Division: New Employee Orientation (Los Angeles), 2001
IRS Appellate Division (Western Region), 2001
IRS Criminal Investigation Division (Hawaii), 2001
IRS Compliance Division (Hawaii), 2002
Hawai'i Tax Department, 2002, 2005
Hawai'i Attorney Generals Office, 2001
UCLA Extension - Attorney Assistant Training Program (Estate Planning), 1988 - 2009
Golden Gate University, Graduate School of Taxation
Core Adjunct Professor, 1996 - 1999
Adjunct Professor, 2000 - present
Hawai'i Association of Pubic Accountants, 2010
Hawai'i Society of Enrolled Agents, 2007
Annual Meeting of the California Tax Bars, 1997 - present
States Abusive Tax Shelter Symposium, 2003, 2004
Hawai'i Society of CPAs Annual Tax Conference, Panel Presentation,1999- 2003,2005, 2007, 2009, 2010
Hawai'i Society of CPAs Tax Controversy Conference, Presentation,1999-2003, 2005, 2007, 2009
Hawai'i Society of CPAs 42nd Annual Conference, Keynote Presentation, 2002
National Association of State Bar Tax Section Chairs, 1999, 2004
ABA Taxation Section, Mid-Year Meeting, 2000, 2003-2011
ABA Taxation Section, Fall Meeting, 2002-2011
ABA Taxation Section, May Meeting, 2003-2011
California Tax Policy Conference,1998, 2002-2004
California CPA Education Foundation Tax Update and Planning Conference, 1999 - 2007, 2009, 2012
California CPA Education Foundation Closely Held Business Conference, 2007
California CPA Education Foundation Tax and Financial Planning for High Net Worth Individuals Conference, 2000, 2003, 2004
California CPA Education Foundation Family Law Conference, 1997, 1999 - 2000
California CPA Education Foundation Financial Statement and Tax Fraud Conference, 2001-2003, 2005, 2006.
Los Angeles Times/Morningstar 5th Annual Investment Strategies Conference, 2001
Los Angeles Times/Morningstar 4th Annual Investment Strategies Conference, 2000
Los Angeles Times/Morningstar 3rd Annual Investment Strategies Conference, 1999
Education:
New York University (LL.M. in Taxation)
Pepperdine University (J.D., cum laude)
University of California at Los Angeles (B.A., Economics)
Bar Admittance:
U.S. Court of Appeals, Fifth and Ninth Circuits
U.S. District Court, Central, Eastern, Northern and Southern Districts of California
U.S. District Court, District of Arizona
U.S. District Court, District of Hawaii
U.S. Court of Federal Claims
U.S. Tax Court
State Bar of California
State Bar of Hawai'i
State Bar of Arizona (Inactive)
Lecturer: "Ethical Representation: Where Do You Draw the Line?" 2012: "IRS Voluntary Disclosures Demystified" 2012; "International Tax Enforcement" 2012; "IRS Audit Issues of Interest to Estate Planners" 2012; "IRS Audit Issues of Interest to Estate Planners" 2012; "Hot Topics in IRS Audits: Strategic Options for Taxpayers" 2012; "Taxpayer Representation 101" 2012; "Documenting Your Tax File" 2012; "Professional Considerations During an IRS Examination" 2011; "IRS Audit Issues & Hot Topics" 2011; "Ethical And Professionalism Considerations In The Tax Controversy Setting " 2011; "Hot IRS Audit Issues" 2011; "Understanding International Tax Evasion and How to Detect it Across Jurisdictions" 2011;"How Panamanian Bankers Can Reduce Risks Associated with FATCA Understanding the Individual and Institutional Liabilities and Responsibilities" 2011; "Ethics and Federal Tax Practice"2011; "Non-Traditional Tax Update" 2011; "Representation 101" 2011-2012; "Cash Reporting and Reporting Requirements for Foreign Financial Accounts" 2011-2012; "IRS Audit Issues & Hot Topics of Interest to Estate Planners"2011;"The New IRS FBAR 2011 Offshore Voluntary Disclosure Initiative (OVDI)," 2011; "IRS Wealth Squad Examinations," 2010; "IRS Enforcement Priorities," 2010; "Foreign Financial Accounts and the IRS," 2010;"Regulation of Return Preparers," 2010; "Practitioner Standards, Penalties & Enforcement Initiatives - Lessons for Estate Planners," 2010; "Foreign Account Reporting and Compliance Update," 2010;"Dealing with the IRS in Changing Times," 2010; "Current IRS Enforcement Priorities and Defensive Strategies," 2010; "What is the IRS Auditing?"2010; "Understanding the AML Departments Role in Detecting and Preventing Tax Evasion in the New Enforcement Climate," 2010; "IRS Enforcement Workshop & Best Tax Ideas Panel," 2010;"Taxpayer Representation: Basic Overview of the IRS Examination Process; 2010; "IRS Appeals "IRS Enforcement," 2009; "Circular 230 - Best Practices!" 2009;"IRS Tax Controversies," 2009; "Special Civil and Voluntary Disclosures of Undeclared Accounts,"2009; "IRS Enforcement in a Declining Economy," 2009; "Taxpayer Representation Workshop: Strategic Options for Audits, Administrative Appeals and Settlements," 2009;" IRS Enforcement Priorities, Initiatives & Strategies," 2009; "Tax Practitioner Penalties & Sanctions,"2008;"IRS Enforcement Priorities: Staying Out of the Line of Fire!"2008; "Tax Practitioner Penalties," 2008; "Lessons on Tax Compliance," 2008;"The New Preparer Penalties: Living in a More Likely Than Not World,"2008; "Strategies and Techniques in Tax Controversy and in Tax Court Litigation," 2007;"New Developments at the IRS affecting Non-Profit Organizations," 2007;"Current Enforcement Priorities of the IRS: Estate, Gift and Income Tax" 2007;"Estates and Trusts - Beyond the Basics" 2007; "California Residency Issues for Entertainers and Athletes," 2007; "Effective Representation of Taxpayers & Current IRS Enforcement Priorities" 2007; "A Temporary and Transitory Visit With California Residency" 2007; "Innocent Spouse: Untying the Tax Knot" 2007; "Follow the Dollar to Schedule C" 2007; "Tax Controversy Update"2006; "Ethical Issues that Arise in a Transactional Tax Practice," 2006; "Minimizing Exposure to Scrutiny in Your Clients Wealth Transfer Strategies - Views From the Tax Court and the IRS," 2006;"Hot Audit Issues: Taxes, Currency Violations, and California Residency !"2006; "Tax Litigation Update," 2006; ""Hot IRS and FTB Audit Issues: Taxes, Currency Violations, California Residency and Your Practice" 2006; "Circular 230 - What Every Tax Practitioner should Know," 2005;"New IRS Initiatives in Audits/Examinations and Collections," 2005; "IRS Tax Controversy Update," 2005; "Life Beyond the Audit and Collections: New Developments in IRS Appeals and Tax Litigation," 2005; "Enhanced IRS Enforcement," 2005;"A Temporary and Transitory Visit With California Residency," 2005; "Structuring Transactions and Currency Violations: The Tax Crime of the Future," 2005; "Discretionary Sentencing for Tax Defendants," 2005; "Proceed With Caution: Structuring Transactions and Currency Violations,"2005; "Money Laundering, Structuring Violations and Tax Evasion," 2005; "Strategic Options for Taxpayers: Audits, Settlements and Litigation," 2004;"States Abusive Tax Shelter Symposium: Techniques Being Used by Different States to Address Tax Shelters," 2004; "Enforcement Tools and Techniques of the Internal Revenue Service and the California Franchise Tax Board," 2004; "International Tax Enforcement," 2004; "Representing Clients Before the IRS and in the U.S. Tax Court," 2004; "Structuring Transactions and Currency Violations: the Tax Crime of the Future !," 2004;"Strategies and Pitfalls in Resolving Structured Listed Transactions," 2004;"OVCI: Analyze That !" 2004; "Current Issues Involving Tax Shelters," 2004; "Current IRS Enforcement Issues For The Coming Year !" 2004;"Tax Enforcement in the Trenches: From the Government and Private Practitioner Perspectives !," 2004; "California Abusive Tax Avoidance Transaction Legislation," 2004; "Technical Tax Shelters: Cutting Edge Techniques and the IRS Response" 2003; "Trends in IRS Enforcement," 2003; "Technical Tax Shelter Enforcement," 2003; "Federal Tax Controversy Update," 2003; "Enhanced IRS Enforcement Efforts," 2003; "Defending Technical Tax Shelters: FTB Abusive Tax Schemes Symposium," 2003; "Voluntary Disclosure - Still a Viable Alternative ?" 2003; "Sensitive Issue Audits: Practical and Ethical Considerations,"2003-2004; "Current Developments in IRS Examinations and Collections,"2002;"Practice Development in a Changing Marketplace," 2002; "Financial and Tax Crimes Following the Apparent Collapse of Professional Integrity," 2002; "IRS Expedited Appeals Procedures" 2002; "2002 Federal Tax Law and Procedural Developments" 2002; "IRS Criminal Enforcement Initiatives" 2002; "A 21st Century Perspective on Tax Practice" 2002; "California Residency for Entertainers and Athletes," 2001; "Estate Planning Under the New Act," 2001;"Hot Topics in IRS Audits," 2001;"Tax Reform: Is It Time ?" 2001; "IRS Appeals Division Customer Service Panel," 2001; "Trusts: Beyond the Basics," 2001;"IRS Compliance New Hire Orientation," 2001; "Fraud and Oversight: The Search for Hidden Assets," 2000; "Innocent Spouse - an Evolutionary Concept," 2000; "Federal and California Tax Procedure in the New Millennium-The IRS and the FTB...Kinder, Gentler, and Still Operating," 2000;"Hot Audit Issues for Trusts and Estates" 2000; "Residency Planning for the Worldwide Citizen", 2000; "Tax Planning: How to Lessen the Tax Bite!", 2000; "ABCs of Voluntary Disclosures", 2000; "IRS Tax Controversy in the New Millennium", 2000; "Trusts: Creation, Administration and Taxation of Grantor, Charitable, Life Insurance and Foreign Situs Trusts", 1999; "Innocent Spouse: What Every Practitioner Should Know", 1999; "Privileged Communications: A Trap For The Unwary Practitioner", 1999; "The Outer Limits of Income Tax Law", 1999; "Ask the Experts: Handling a Sensitive Issue Audit," 1999; "Your Parents Finances: Questions to Ask, Answers to Get", 1999; "California Residency Issues", 1999; "Settling Civil Tax Disputes With the FTB and the SBE", 1999; "IRS Restructuring and Reform Act of 1998 for the Business Manager", 1999; "Planning for Retirement", 1999; "Federal Tax Procedural Roundtable Discussion", 1998, 1999; "The IRS and Your Divorce Client", 1998; "Estate Planning Considerations Arising Out Of the IRS Restructuring and Reform Act of 1998", 1998; "Privileged Communications Under the IRS Restructuring and Reform Act of 1998", 1998; "Overview of the IRS Restructuring and Reform Act of 1998", 1998; "Taxpayer Confidentiality Act of 1998," 1998; "1997 Federal Tax Controversy Institute", 1997; "Recent Developments in Criminal Tax Enforcement", 1997; "Tax Crimes in Family Law Cases," 1995-1997; "Overview of the 1997 Tax Act - Individual Income Tax Issues", 1997; "IRS Corporate Audits", 1997; "Current Developments in Resolving Federal and State Administrative Tax Disputes," 1997-1998; "Traps for the Unwary - IRS Sensitive Issue Audits", 1997; "Privileged Communications in the World of Taxation", 1997; "Entertainment Audit Issues", 1997; "The CPAs Role in Tax Litigation and Controversy", 1996-97; "A Temporary and Transitory Visit With California Residency", 1996-1997; "Taxpayer Bill of Rights II", 1996; "Preparing for IRS Financial Status Audits", 1996; "IRS Project Esquire", 1996; "Taxation of Litigation Damage Awards", 1996; "Nuts and Bolts of State Tax Procedure", 1996; "IRS Financial Status Audits - Avoiding Accountant Malpractice", 1996; "California Tax Settlements", 1996; "Bringing a Crime Sensitive Taxpayer in From the Cold", 1996; "Family Law and the IRS - A Collision of Issues", 1996; "Current Developments in Federal and State Tax Procedure", 1996-1998; "Recent Developments in Tax Procedure and Litigation", 1994-1998; "Selected Topics in Civil and Criminal Tax Practice", 1993-1994; "Sales and Use Tax Procedure Before the State Board of Equalization", 1993-1994.
Author: "Limitations Period for Refund Litigation" CCH Journal of Tax Practice and Procedure, October-November 2012; "Innocent Spouse: Separating the Marital Liability" CCH Journal of Tax Practice and Procedure, August-September 2012; "IRS Provides Updated Guidance Regarding Offshore Voluntary Disclosure Program" CCH Journal of Tax Practice and Procedure, June-July 2012; "Overview of Tax Practice and Procedure" CCH Journal of Tax Practice and Procedure, April-May 2012; "IRS Whistleblower Program: Making Money the Old Fashioned Way!" CCH Journal of Tax Practice and Procedure, April-May 2012; "The 2012 IRS Offshore Voluntary Disclosure Initiative," CCH Journal of Tax Practice and Procedure, February-March 2012; "Practice Tips from the Tax Trenches," CCH Journal of Tax Practice and Procedure, December 2011 - January 2012;"IRS Voluntary Classification Settlement Program," CCH Journal of Tax Practice and Procedure, October- November 2011;"Evaluation of an IRS Undisclosed Offshore Account IDR," Tax Notes Column, November 2011;"Everything is Fine . . .Until it Isnt," AICPA, October 2011; "A Fresh Start for Struggling Taxpayers," CCH Journal of Tax Practice and Procedure, June-July 2011; "The IRS 2011 Offshore Voluntary Disclosure Initiative," LA Lawyer, June 2011; "Enhancing Voluntary Compliance Through the Administration of Civil Tax Penalties," CCH Journal of Tax Practice and Procedure, April-May 2011; "The Last, Best Chance to Disclose Foreign Financial Accounts and Assets-The 2011 Offshore Voluntary Disclosure Program and Beyond!," CCH Journal of Tax Practice and Procedure, February-March 2011; "Final Uncertain Positions Filing Requirements: IRS Addresses Key Concerns," CCH Journal of Tax Practice and Procedure, October-November 2010; "IRS Global High-Wealth Industry Group: Evaluation of an IRS Wealth Squad IDR," Tax Notes Column, November 2010; "Basic Audit Techniques: Taxpayer Interviews,"CCH Journal of Tax Practice and Procedure, August-September 2010; "FOIA Requests: A Look Into the IRS Examination File,"Tax Notes Column, August 2010; "Holistic Audits: The Price of Being Rich,"CCH Journal of Tax Practice and Procedure, June-July 2010; "A Return to Troy: QARS and the Civil Fraud Exception," Tax Notes Column, June 2010; "The IRS Takes a Controversial Position on Uncertain Tax Positions" CCH Journal of Tax Practice and Procedure, April-May 2010, "IRS Return Preparer Strategy: Leveraging Limited Tax Enforcement Resources Through the Registration and Education of the Return Preparer Community," CCH Journal of Tax Practice and Procedure, February-March 2010; "Tax Enforcement: Reading Tea Leaves in a Tax Gap" Tax Notes Column, March 2010;"Epilog: The Voluntary Disclosure of Offshore Accounts," CCH Journal of Tax Practice and Procedure, December 2009-January 2010; "Meet the New Director of the Office of Professional Responsibility: An Interview with Karen L. Hawkins," CCH Journal of Tax Practice and Procedure, "August-September 2009; "Continuing IRS Guidance for the Voluntary Disclosure of Offshore Accounts," CCH Journal of Tax Practice and Procedure, June-July 2009; "The End of an Era: The IRS Closes in on Offshore Bank Accounts,"CCH Journal of Tax Practice and Procedure, April-May 2009; "Practitioner Penalties: Potential Pitfalls in the Tax Trenches," Tax Notes, April 2009; "Counseling Corporations Involved in Government Investigations and the Principles of Federal Prosecution of Business Organizations," Corporate Business Taxation Monthly, February 2009; "Update:Estate Planners as Return Preparers - Increased Penalty Exposure and the New Final Regulations," CCH Estate Planning Monthly, February 2009; "United States v. Stein: The Second Circuit Affirms," CCH Journal of Tax Practice and Procedure, October-November 2008; "Estate Planners as Return Preparers: Increased Penalty Exposure and the New Proposed Regulations,"CCH Financial and Estate Planning Reporter, July 2008; "Lichtenstein Accounts, German Spies and Now the IRS?," CCH Journal of Tax Practice and Procedure, June-July 2008 ;"Worker Classification:IRS Launches Questionable Employment Tax Practice Initiative," CCH Journal of Tax Practice and Procedure, February-March 2008 ;"Textron: Careful Reasoning for a Challenging Issue," CCH Journal of Tax Practice and Procedure, December 2007-January 2008;"The Increasingly Risky Business of Tax Gap Evasion and Voluntary Disclosure," CCH Journal of Tax Practice and Procedure, October-November 2007;"Currency Reporting Requirements: Everyone into the Pool!" "CCH Journal of Tax Practice and Procedure, June-July 2007; "Civil and Criminal Tax Considerations in a Marital Dissolution," Hawaii State Bar Journal, July 2007; "IRS Enforcement: The Pendulum Has Swung Too Far!"CCH Journal of Tax Practice and Procedure, April-May 2007; "Expedited Fraud Examinations: A Call for the Return to the Rack and Screw!"CCH Journal of Tax Practice and Procedure, February-March 2007; "Tax Practitioners Guidebook: Picking Up Scraps From the Table" Tax Analysts - Tax Practice, 2007; "Federal Prosecutions of Business Organizations - Comparing McNulty to Thompson" CCH Journal of Tax Practice and Procedure, December 2006-January 2007; "Non-Filers Beware: Whos That Knocking at Your Door?" CCH Journal of Tax Practice and Procedure, October-November 2006; "Identity Theft: Phishing on the Internet" KALA Hawaii Society of CPAs, July 2005 "Throwing Peanuts From The Bleachers: Federal Prosecutions of Business Organizations." CCH Journal of Tax Practice and Procedure, June-July 2006; "Series LLCs: Fact or Fiction?" KALA Hawaii Society of CPAs, June 2006; "Strategic Options for Taxpayers - California Tax Procedure 101,"California Tax Lawyer, Winter 2006; "Back to the Future! Tax Practice Suggestions" CCH Journal of Tax Practice and Procedure," April-May 2006; "Targeting the Representative," California State Bar, Tax Procedure & Litigation Subcomittee Newsletter, May 2006;"Crossing the Rubicon - A Lesson in Accountability" CCH Journal of Tax Practice and Procedure," January 2006; "Money Laundering, Structuring Violations and Tax Evasion," KALA Hawaii Society of CPAs, May 2005;"Structuring Transactions and Currency Violations," CCH Journal of Tax Practice and Procedure, March 2005;"Responsible Tax Enforcement and the Uncertainties of Litigation," CCH Journal of Tax Practice and Procedure, January, 2005; "A Temporary and Transitory Visit With California Residency," California Tax Lawyer, January 2005; "Strategic Options for Taxpayers - Federal Tax Procedure 101,"CCH Journal of Tax Practice and Procedure, January, 2005; "Surviving an Income Tax Audit", The Tax and Business Advisor Library, Commerce Clearing House, 2000; "Wheres the Beef ? Evaluation of a Recent IRS Settlement Initiative," CCH Journal of Tax Practice and Procedure, June-July, 2004; "Technical Tax Shelters - From the Trenches: Enhanced IRS Enforcement and the Uncertainties of Litigation." CCH Journal of Tax Practice and Procedure, October 2003;"IRS Revised Voluntary Disclosure Policy: Feel Lucky?," CCH Journal of Tax Practice and Procedure, June 2003; "IRS Revised Voluntary Disclosure Policy: A Charge to Offshore Credit Cards," LA Lawyer, 2003;"The Life and Death of Estate Taxes," LA Lawyer, 2001; "Unanticipated Tax Considerations In A Marital Dissolution," KALA Hawaii Society of CPAs, March 2001;"IRS MSSP Program: Examination Techniques Revealed !" KALA Hawaii Society of CPAs, February 2001;"Audit Overhaul: IRS Examiners Become Experts in Industry Sectors to Reduce Noncompliance," Los Angeles Daily Journal, January 2001; "Audits of Professional Sports Franchises," CCH Journal of Tax Practice and Procedure, March 2000; "Assisting Pro Se Taxpayers", CCH Journal of Tax Practice and Procedure, November 1999; "A Visit With Timothy Boyer, Chief Counsel, State Board of Equalization", California Tax Lawyer, 1999; "Overview of Federal and California Tax Procedure", California Tax Lawyer, 1998; "A Visit With Franchise Tax Board Chief Counsel Brian Toman", California Tax Lawyer, 1998; "A Temporary and Transitory Visit With California Residency", Los Angeles Lawyer, September 1997; "IRS is Watching Your Clients Marital Dissolution", Lawyers World, March/April 1997; "Financial Status Audits: The Internal Revenue Service Returns to Basic Investigative Techniques", The Federal Lawyer, August 1996; "Financial Status Audits: A Return to Basic Investigative Techniques", The Attorney-CPA, November 1996; "IRS and EDD Implement New Approach to Worker Classification", The Tax Reporter, August 1996; "The EDD Implements its New Tax-Settlement Authority", Los Angeles Lawyer, May 1996; "Economic Reality and the Internal Revenue Service", California Tax Lawyer, November 1995; "Deductibility of Client Costs by a Law Firm", The Tax Reporter, July 1995; "Privileged Communications", The Tax Reporter, October 1995. Co-Author: CCH Expert Treatise Library: Tax Practice & Procedure, 2012; "Tax Crimes", Bureau of National Affairs - Tax Management, Publication 636 (1993, revised 2012); "Current IRS Enforcement Issues For The Coming Year," Matthew Bender & Company, 2004.
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