Our Firm Sandra R. Brown

brown@taxlitigator.com Phone: (310) 281-3200
Fax: (310) 859-5105

Sandra R. Brown has joined the firm as a principal after serving most recently as the First Assistant United States Attorney for the Central District of California. Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.

From March 2017 to January 2018, Ms. Brown served as the Acting United States Attorney. In addition to leading the Central District of California’s United States Attorney’s Office, where she supervised approximately 270 attorneys in the largest Justice Department Office outside of Washington D.C., Ms. Brown also served as the Chief of the Tax Division for more than ten years where she supervised lawyers within the United States Attorney’s Office, the Department of Justice Tax Division and the Department of Treasury who were responsible for complex Federal civil and criminal tax matters, including related grand jury proceedings, trials and appeals.

In her more than 26 years as a federal trial lawyer, Ms. Brown obtained a vast expanse and depth of experience in complex civil and criminal tax matters, having personally handled over 2,000 cases on behalf of the United States before the United States District Court, the Ninth Circuit Court of Appeals, the United States Bankruptcy Court, the United States Bankruptcy Appellate Panel and the California Superior Court. Those cases included nationally significant civil tax cases such as two Supreme Court decisions and a multitude of published 9th Circuit decisions, as well as a broad range of equally noteworthy criminal tax cases including the first of the recent FBAR prosecutions in California, one of the largest individual tax restitution judgments fully recovered in a criminal tax case prosecuted in this nation, and the unprecedented deferred prosecution agreement, resolving a criminal probe into an international bank’s worldwide U.S. cross-border business, requiring the bank to pay $270 million in restitution and fines and to provide details about employees and more than 1,500 U.S. customers.

In addition to other honors, commendations and awards, Ms. Brown has received the Internal Revenue Service Criminal Investigation Chief’s Award and the IRS’s Mitchell Rogovin National Outstanding Support of the Office of Chief Counsel Award, respectively, the most prestigious criminal and civil awards available for presentation by the IRS to Department of Justice employees.

Ms. Brown has written, lectured and taught federal prosecutors, agents and private practitioners throughout the country on topics involving trial strategies, taxation, bankruptcy and money laundering.  Based upon the breadth of her expertise and experience in litigation and management, Ms. Brown is a highly sought-after speaker before national and regional professional organizations.

Government Experience

  • Acting United States Attorney, Central District of California, Office of the United States Attorney, March 2017 – January 2018
  • First Assistant United States Attorney, Central District of California, Office of the United States Attorney, January 2018- March 2018; April 2016-March 2017
  • Assistant United States Attorney, Central District of California, Tax Division, Office of the United States Attorney, June 1991-April 2016

o   Chief of Tax Division, 2004-2016
o   Deputy Chief, Criminal Tax Matters, 2003-2004

Speaking Engagements

  • Moderator and Co-Chair, Criminal Tax Workshop, 34rd Annual National Institute on Criminal Tax Fraud and 7th Annual National Institute on Tax Controversy, 2017
  • Panelist, DOJ Roundtable, 34rd Annual National Institute on Criminal Tax Fraud and 7th Annual National Institute on Tax Controversy, 2017
  • Panelist, Representing the World Citizen: Criminal Tax Defense in a World Where Persons, Money and Data are Mobile, 34rd Annual National Institute on Criminal Tax Fraud and 7th Annual National Institute on Tax Controversy, 2017
  • Speaker, Keynote Address, United States Attorney’s Office, 1st Annual Conference on Prosecuting Federal Human Trafficking Crimes, 2017
  • Speaker, Keynote Address, United States Attorney’s Office, 1st Annual Conference on Prosecuting Federal Hate Crimes, 2017
  • Speaker, Keynote Address, California Gang Investigators Association, 26th Annual National Gang Conference, 2017
  • Lecturer, Federal Tax Information, Section 6103, U.S. Department of Justice’s National Advocacy Center: Criminal Tax Seminar, 2016
  • Lecturer, Introduction to Criminal Tax Prosecutions, U.S. Department of Justice’s National Advocacy Center: Criminal Tax Seminar, 2016
  • Lecturer, Section 363 Sales, U.S. Department of Justice’s National Advocacy Center: Advanced Bankruptcy Seminar, 2016
  • Lecturer, Sentencing & Restitution in Criminal Tax Cases, U.S. Department of Justice’s National Advocacy Center: Criminal Tax Seminar, 2016
  • Moderator and Chair, Criminal Tax Workshop, 33rd Annual National Institute on Criminal Tax Fraud and 6th Annual National Institute on Tax Controversy, 2016
  • Moderator and Panelist, DOJ Roundtable, 33rd Annual National Institute on Criminal Tax Fraud and 6th Annual National Institute on Tax Controversy, 2016
  • Panelist, Ask the Experts: Top Tips for Criminal Tax Cases, 33rd Annual National Institute on Criminal Tax Fraud and 6th Annual National Institute on Tax Controversy, 2016
  • Panelist, Post-Return Conduct Impacting the Civil and Criminal Case, 2015 Annual Tax Controversy Institute, UCLA Extension
  • Panelist, Criminal Tax Workshop, 2015 Annual Meeting of the California Tax Bar & California Tax Policy Conference
  • Panelist, Federal Procedural Roundtable, 2015 Annual Meeting of the California Tax Bar & California Tax Policy Conference
  • Panelist, Criminal Tax Workshop, 32rd Annual National Institute on Criminal Tax Fraud and 5th Annual National Institute on Tax Controversy, 2015
  • Panelist, DOJ Roundtable, 32rd Annual National Institute on Criminal Tax Fraud and 5th Annual National Institute on Tax Controversy, 2015
  • Panelist, Sentencing: Best Practices in a Changing Landscape, 32rd Annual National Institute on Criminal Tax Fraud and 5th Annual National Institute on Tax Controversy, 2015
  • Panelist, Ask the Experts: Top Criminal Tax Practice Tips and Representation Strategies, 31st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, 2014
  • Panelist, Criminal Tax Workshop, 31st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, 2014
  • Panelist, Where did the money go, and How will the Government find it? 31st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, 2014
  • Panelist, Stolen Identity Refund (“SIRF”), 2014 USC Gould School of Law Tax Institute
  • Speaker, Keynote Address, 50th Annual Hawaii Tax Institute, 2013
  • Panelist, Restitution in Sentencing and Civil Tax Issues, ABA Section of Taxation, Section Litigation, and the ABA Center for Professional Development, 2013
  • Panelist, Criminal Tax Workshop, 30st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, 2013
  • Panelist, DOJ Roundtable, 30st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, 2013
  • Panelist, Ask the Experts: Top Criminal Tax Practice Tips and Representation Strategies, 30st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, 2013
  • Panelist, U.S. Tax Enforcement and the Voluntary Disclosure Process, 2012 Annual Tax Controversy Institute, UCLA Extension
  • Panelist, Criminal Tax Workshop, 29th Annual National Institute on Criminal Tax Fraud and 3rd Annual National Institute on Tax Controversy, 2012
  • Panelist, Foreign Financial Accounts, 29th Annual National Institute on Criminal Tax Fraud and 3rd Annual National Institute on Tax Controversy, 2012
  • Panelist, Civil Tax Issues and Restitution in Sentencing, ABA Section of Taxation, Civil & Criminal Tax Penalties Committee, 2012
  • Speaker, Interview & Testimony Tips for Special Agents, IRS, Criminal Investigation, 2012
  • Speaker, Successful Investigations, Successful Prosecutions, IRS, Criminal Investigation, 2012
  • Panelist, Motion Practice, ABA White Collar Conference 2011
  • Panelist, Criminal Tax Workshop, 28th Annual National Institute on Criminal Tax Fraud and 2nd Annual National Institute on Tax Controversy, 2011
  • Panelist, Restitution, 28th Annual National Institute on Criminal Tax Fraud and 2nd Annual National Institute on Tax Controversy, 2011
  • Panelist, Foreign Bank and Financial Accounts Report (“FBAR”), 2011 USC Gould School of Law Tax Institute
  • Guest Lecturer, Tax Crimes, Southwestern Law School, 2010
  • Speaker, Discovery in a Criminal Case, IRS – Criminal Investigation, 2010
  • Panelist, Criminal Tax Workshop, 27th Annual National Institute on Criminal Tax Fraud and 1st Annual National Institute on Tax Controversy, 2010
  • Speaker, Employment Tax Crimes, IRS – Criminal Investigation, 2009
  • Panelist, Federal Sentencing Guidelines, 26th Annual National Institute on Criminal Tax Fraud, 2009
  • Lecturer, Parallel Proceedings: Concurrent Civil & Criminal Investigations, U.S. Department of Justice’s National Advocacy Center: Criminal Tax Seminar, 2009
  • Lecturer, Post-Booker Sentencing in Tax Cases, U.S. Department of Justice’s National Advocacy Center: Criminal Tax Seminar, 2009
  • Speaker, Keynote Address, California CPA, 2008 Fraud in Audit, Accounting and Tax Conference
  • Speaker, Keynote Address, 2007 USC Gould School of Law Tax Institute
  • Panelist, Conflicts and Ethical Issues Facing Tax Practitioners, 2007 USC Gould School of Law Tax Institute

Publications

  • FBAR Violations: The IRS’s New Tool for Improved Tax Compliance, Journal of Tax Practice & Procedure, December 2008-January 2009

Member

  • Fellow, American College of Tax Counsel
  • American Bar Association, Tax Section
  • NYU Tax Controversy Institute, Advisory Committee
  • Beverly Hills Bar Association, Taxation Section
  • Federal Bar Association
  • California Lawyers Association, Tax Section
  • Women White Collar Defense Association

Bar Admittance

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

Education

  • LL.M. Taxation, University of Denver
  • J.D., Western Michigan University Cooley Law School
  • B.S. in Business Administration, Central Michigan University