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California Lawyers Association – Members of Hochman Salkin Toscher Perez P.C. Sworn in by the U.S. Supreme Court

We are very pleased to announce that on May 18, 2023, following the success of the firm’s participation in the Taxation Section of the California Lawyers Association’s “DC Delegation,” the following principals and associates of Hochman Salkin Toscher Perez P.C. were sworn in as members of the Supreme Court of the United States by Chief Justice John Roberts. 


Sandra R. Brown

Michel Stein


Garabed “Gary” Markarian

Philipp Behrendt

Chief Justice Roberts was joined by all eight Associate Justices for the swearing in ceremony. Also in attendance in the courtroom was retired Associate Justice Stephen Breyer.

Prior to the Supreme Court swearing in ceremony, our firm, represented by Sandra Brown, Michel Stein, Gary Markarian, Philipp Behrendt, along with Robert Horwitz, Edward Robbins and Michael Greenwade, met with government officials from the Department of Treasury, Internal Revenue Service, Department of Justice Tax Division, Joint Committee on Taxation, House Ways and Means and the Senate Finance as part of the “DC Delegation” and presented three separate papers all of which focused on advocating for improvements in various aspects of federal tax administration, including partnership audits, “safe harbor” penalty relief for appraisers and due process changes to the IRS’s assertion of certain foreign penalties. Additionally, several of our attorneys were invited to orally contribute to presentations by other members of the Tax Section which were focused on FATCA loopholes and digital asset “ponzi scheme” losses.

Judicial Jurisdiction for Assessable and Foreign Information Penalties

IRC Section 6695A Penalties

BBA Imputed Underpayment Abuse of Discretion


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