Our Firm Dennis L. Perez

perez@taxlitigator.com Phone: (310) 281-3200
Fax: (310) 859-1430 Download Vcard

Dennis L. Perez represents and advises U.S. taxpayers in foreign and domestic voluntary disclosures, sensitive issue civil tax examinations where substantial civil penalty issues or possible assertions of fraudulent conduct may arise, and in defending criminal tax fraud investigations and prosecutions. Mr. Perez is highly respected for his calm demeanor, judgment and extensive experience in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral from the Internal Revenue Service.

Mr. Perez, a former senior trial attorney with IRS District Counsel in Los Angeles, CA.  He has extensive experience in the representation of clients in civil, administrative tax and criminal tax disputes and controversies before the Internal Revenue Service, the Tax Division of the U.S. Department of Justice, the California Franchise Tax Board, the California State Board of Equalization, and the California Employment Development Department.  Dennis Perez is a member of the Planning Committee of the UCLA Extension Annual Tax Controversy Institute and is also a Certified Specialist, Taxation Law, State Bar of California, Board of Legal Specialization.

Mr. Perez frequently lectures on advanced tax procedure topics at various seminars and before state and local bar associations and professional accounting groups. He was instrumental in the creation of the United States Tax Court “Pro Se Video” sponsored by the Taxation Section of the State Bar of California. He was also instrumental in creating an experimental Settlement Judge Procedure for the United States Tax Court. Mr. Perez is the first ever recipient of the Los Angeles Lawyer Sam Lipsman Service Award. This award was established in memory of the  late publisher Sam Lipsman, to honor an Editorial Board member or author who has provided exemplary service on behalf of Los Angeles Lawyer.  Dennis Perez is a past Vice-Chair of the Executive Committee of the Taxation Section of the State Bar of California and is member of the Tax Procedure and Litigation Subcommittee of the Taxation Section of the State Bar of California; the Past-Chair of the Tax Procedure and Litigation Subcommittees of both the Taxation Section for the State Bar of California and the Los Angeles County Bar Association and he is the Past-Chair of the Los Angeles Lawyer Magazine, the magazine for the Los Angeles County Bar Association. He is also a member of the Association of Tax Counsel. Mr. Perez is a Past-President of the UCLA Law School Alumni Board and lecturer for the UCLA School of Law and is an Adjunct Professor, Golden Gate University, Graduate School of Taxation (1999 to present).

Presentations:

  • June, 2019 – Current IRS Enforcement Objectives, Ways in which IRS Detects and Pursues these Objectives and Taxpayer Defense Alternatives, Oregon Tax Institute
  • December, 2018 – Ethical and Other Issues When Representing Non-Compliant Taxpayers: Domestic and Foreign Voluntary Disclosures In a Post-Program World, ABA 35th National Institute on Criminal Tax Fraud and 8th Annual National Institute on Tax Controversy
  • October, 2018 – Goodbye Offshore Voluntary Disclosure Program Hello Litigation of International Reporting Penalties, UCLA 34th Annual Tax Controversy Institute
  • July, 2018 – Beware of Kovel Accountants – Presentation to KKB
  • May, 2018 – Representing Taxpayers in Collection Matters Before the IRS, Presentation to KKB
  • May, 2018 – Civil and Criminal Employment Tax Enforcement Efforts Employers Beware, ABA Tax Section Webinar
  • January, 2018 – California Non-Residency Determinations A Temporary and Transitory Visit with California Residency
  • November, 2017 -From the Experts: IRS Representation Tool, Techniques and Defensive Strategies – Civil & Criminal Tax Update, 76th NYU Institute on Federal Taxation
  • October, 2017 – Capturing the Small Captive Insurance Company, UCLA 33rd Tax Controversy Institute
  • August, 2017 – From the Trenches 150+ Years of Tax Disputes, California Society of CPAs
  • August, 2017 – Captive Insurance Tax Controversies, RJS Law Tax Controversy Institute
  • December, 2016 – SD US – Mexico Conference & Professional Issue – CalCPA Education Foundation
  • May, 2016 – Civil and Criminal Employment Tax Enforcement Efforts – Employers Beware, ABA Tax Section Webinar
  • January, 2016 – Tips From The Trenches and IRS Examination Collection  Representation, USC Gould 2016 Tax Institute
  • November, 2015 – Tax Affecting S Corporation for Business Valuations – Cases, BHBA The 41st Annual Family Law Symposium
  • November, 2015 – Perfect Your Advocacy Skills & Develop Advanced Trial Techniques, 2015 Annual Meeting of the CA Tax Bar
  • November, 2015 – Disclosures and Their Impact on Statutes of Limitation and Penalties on Estate and Gift Tax Returns and Related Issues, Jewish Community Foundation Lecture
  • October, 2015 – My Tax Court Case Is Calendared.  Now What Do I Do,? 2014 Annual Meeting of the CA Tax Bar
  • November, 2014 – My Tax Court Case Is Calendared.  Now what do I do?, 2014 Annual Meeting of CA Tax Bar
  • June, 2014 – 2014 CA Tax Practitioner’s Conference, LA County Bar
  • June, 2014 – 2014 Cross-Border Compliance & Enforcement, STEP LA 2014
  • April, 2014 – AFDA’s White Collar Roundtable Webinar
  • July, 2009  – LA Taxation Committee – IRS Enforcement in the Tax Gap, CALCPA Lecture
  • January, 2009 – Litigating Employee or Independent Contractor Status – A View from The Trenches
  • January, 2009 -Labor & Employment Relations Association Annual Meeting
  • October, 2008 – Worker Classification and Techniques, UCLA Tax Controversy Institute
  • October, 2008 – Criminal Tax Enforcement, CAL State LA
  • July, 2008 – Enforcement Activities & Initiatives at the IRS, FTB and EDD,
    CALCPA Lecture
  • August, 2007 – Current Enforcement Priorities of the Internal Revenue Service and Franchise Tax Board,  Santa Barbara Society CPA
  • March, 2007 – Estate Planning in the Crucible: How to Defend an Estate Plan in Appeals and in the Tax Court, Society of Trust and Estate Practitioners USA
  • February, 2007 – Litigation of an Income Tax Case Before the U.S. Tax Court, Beverly Hills Bar Association
  • March, 2004 – Federal Tax Update, CPA/Law Society of Ventura County
  • November, 2003 – Federal Tax Controversy Update, Santa Barbara County Bar Association
  • October, 2003 – Jobs and Growth Tax Relief and Reconciliation Act of 2003 and Other Recent Tax Developments,  Cal State University, Los Angeles
  • March, 2003 – Federal Tax Litigation Update, CPA/Law Society of Ventura County
  • June, 2003 – New Federal Tax Legislation/Income Tax Update, Whittier Law School 2002 Annual Income Tax Seminar
  • 2003 – Individual Tax Update, Cal State University, Los Angeles
  • November, 2002 – Federal Tax Litigation Update: Innocent Spouse, Employment Taxes, Criminal Enforcement Initiatives and Related Areas,  Central Coast CPA/Law Society
  • November, 2002 – IRS Enforcement,  California CPA Education Foundation
  • March, 2002, Federal Tax Litigation Update: Innocent Spouse, Employment Taxes
    Criminal Enforcement Initiatives and Related Areas
    March, 2002 – Ventura County CPA/Law Society
  • February, 2002 – Current Developments in Internal Revenue Service
    Criminal Investigation Enforcement Initiatives and Cases, Center for International Legal Studies

Publications:

  • Co-Author: “Recently Proposed Amendment to the Federal Sentencing Guidelines Affect Criminal Tax Cases” with Steven Toscher, CCH Journal of Tax Practice and Procedure, December 2012-January 2013
  • Co-Author: “What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account?” with Edward Robbins, Jr. and Steven Toscher, CCH Journal of Tax Practice & Procedure, October-November 2012
  • Co-Author: “Tax Crimes”, Bureau of National Affairs (BNA) – Tax Management, Publication 636 (1993, revised 2012).
  • Co-Author: “IRS Audits of Attorneys’ Tax Returns” with Lacey Strachan, Los Angeles Lawyer, April 2012
  • Co-Author: “The IRS 2011 Offshore Voluntary Disclosure Initiative” with Charles P. Rettig, Los Angeles Lawyer, June 2011
  • Author: “New Tax Relief for Victims of Ponzi Schemes,” Los Angeles Lawyer, October 2009
  • Co-Author: “Counseling Corporations Involved in Government Investigations and the Principles of Federal Prosecution of Business Organizations” with Charles Rettig, Steven Toscher, and Edward M. Robbins, Jr., Corporate Business Taxation Monthly, February 2009
  • Co-Author: “Sentencing Discretion After Booker and the IRS/DOJ Expedited Plea Program” with Steven Toscher, CCH Journal of Tax Practice and Procedure, December 2005-January 2006
  • Co-Author: “Discretion is Back in the Sentencing of Tax Defendants–At Least for Now” with Steven Toscher, BNA Tax Management, February 2005
  • Author: “2005 California Tax Amnesty,” Tax Tips, Los Angeles Lawyer, December 2004
  • Co-Author: “How the IRS Distinguishes Civil and Criminal Tax Fraud” – L.A. Lawyer – October, 2003
  • Co-Author: “The Crime Fraud Exception to the Attorney-Client Privilege”, CCH Journal of Tax Practice and Procedure (June 2000)
  • Author: U.S. Tax Court Settlement Judge Procedure, California State Bar Taxation Section, Washington D.C. Trip, (May 1996)

Honors And Affiliations:

  • First recipient of the Sam Lipsman Service Award
  • Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization
  • Elected Fellow, American College of Tax Counsel
  • United States Tax Court Judicial Conference, 1997, 2003, 2007
  • Adjunct Professor, Golden Gate University Graduate School of Taxation (1999 to present)

Member:

  • Chair, Los Angeles Lawyer Editorial Board
  • President, UCLA Law School Alumni Board of Directors
  • Member, Los Angeles Lawyer Editorial Board
  • Fellow, American College of Tax Counsel
  • Past Chair, State Bar of California Tax Procedure & Litigation Subcommittee
  • Past-Chair of the Tax Procedure & Litigation Subcommittee of the Los Angeles County Bar Association
  • Member, Association of Tax Counsel
  • Second Vice-Chair Taxation Section, Executive Committee, California State Bar
  • Planning Committee of the UCLA Extension Annual Tax Controversy Institute
  • National Association of Criminal Defense Lawyers
  • Producer, U.S. Tax Court Pro Se Video

Bar Admittance:

  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. Tax Court
  • U.S. District Court for Central, Eastern and Southern Districts of California
  • State Bar of California

Education:

  • University of California, Los Angeles (J.D.)
  • San Diego State University (A.B. English Cum Laude)



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