California Lawyers Association – 2025 DC Delegation
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Wednesday, April 30, 2025
We are pleased to announce that Sebastian Voth and Philipp Behrendt of our firm are participating in the California Lawyers Association – Taxation Section DC Delegation on May 5-7, 2025.
For over 30 years, the Taxation Section has annually selected a delegation to present the ideas and proposals of California tax lawyers to officials in Washington, D.C. This opportunity allows tax practitioners to present significant issues to key tax officials and staff members from various government offices.
This year, Hochman Salkin Toscher Perez P.C. presented a paper that proposes a legislative amendment to Internal Revenue Code § 6501(c)(1) to protect innocent taxpayers from an unlimited statute of limitations on tax assessments based on the fraudulent intent of a third party, such as a taxpayer’s return preparer. The current Tax Court interpretation allows the statute of limitations to remain open indefinitely when a fraudulent return with intent to evade tax is filed, regardless of whether the taxpayer committed the fraud. The proposal suggests either restricting the fraud exception to cases where the taxpayer intended to evade tax, or alternatively, imposing a six-year limitations cap in cases involving third-party fraud to balance taxpayer rights with IRS enforcement needs.
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
