Our Firm Sandra R. Brown

brown@taxlitigator.com Phone: (310) 281-3200
Fax: (310) 859-5104 Download Vcard

Sandra R. Brown 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

 

Presentations

  • Speaker, Why Your Client’s Chances of Criminal Prosecution and Civil Fraud Penalties has Dramatically Increased – The IRS New Office of Fraud Enforcement, 2021
  • Speaker, The Consequences of Conviction: The U.S. Sentencing Guidelines, Restitution, Forfeiture, and Collateral Consequences, 2020
  • Speaker, Yes, You Actually Can Go to Jail for Not Paying Taxes, OCBA, 2020
  • Speaker, Tax Controversies, NYU Institute on Federal Taxation, 2020
  • Moderator, What Every Practitioner Needs to Know to Protect Their Clients and Themselves from Civil Fraud Penalties and Criminal Investigations, UCLA 36th Annual Tax Controversy Institute, 2020
  • Panelist, When You Need to Disclose More Than Just a Tax Crime, ABA May Meeting, 2020
  • Speaker, Developments in Crypto Currency – Reporting and Enforcement, CPA Academy, 2020
  • Lecturer, Current Developments in IRS Criminal Tax Enforcement, Cal State LA Accounting and Tax Seminars, 2019
  • Speaker, New Developments in Criminal Tax Enforcement, ABA 33rd Annual National Institute on White Collar Crime, 2019
  • Speaker, Criminal Trial Practice, 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, 2018
  • Co-Moderator, Criminal Tax Workshop, 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, 2018
  • Panelist, Webcast Series Covering Defense of Criminal Tax Cases, Association of Federal Defense Attorneys, 2018
  • Moderator and Co-Chair, Criminal Tax Workshop, 35th Annual National Institute on Criminal Tax Fraud and 7th Annual National Institute on Tax Controversy, 2017
  • Panelist, DOJ Roundtable, 34th 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, 34th 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, 32nd Annual National Institute on Criminal Tax Fraud and 5th Annual National Institute on Tax Controversy, 2015
  • Panelist, DOJ Roundtable, 32nd Annual National Institute on Criminal Tax Fraud and 5th Annual National Institute on Tax Controversy, 2015
  • Panelist, Sentencing: Best Practices in a Changing Landscape, 32nd 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, 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

IRS Cracks Down on Tax Fraud by Creating a New Enforcement Office, Los Angeles Lawyer, June 2020

A Taxing Impediment, Los Angeles Lawyer January 2019

The Future of Virtual Currency Tax Prosecutions – A Matter of When, Not If, Journal of Tax Practice and Procedure, December 2018-January 2019

When Noncompliance With FATCA Is More Than a Civil Tax Matter, Tax Notes, November 2018

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

 

Blogs

02/08/21          The Corporate Transparency Act takes on Serious Tax Fraud: Say Goodbye to Not Disclosing Beneficial Owners of Entities by Sandra R. Brown and Michael Greenwade

12/15/20          The Due Process Protections Act of 2020 – Judicial Oversight for Federal Prosecutors by Sandra Brown

11/09/20          Sandra Brown to speak on “The Consequences of Conviction: The U.S. Sentencing Guidelines, Restitution Forfeiture, and Collateral Consequences” at The IRS Representation Conference webcast

10/26/20          Sandra Brown to speak on  “From the Experts: Tax Controversy and Tax Litigation – Civil and Criminal Tax Update” at the NYU 79th Virtual Institute webinar on November 16, 2020

10/06/20          What Makes a Failure to File Your Tax Returns a Felony? By Sandra Brown

09/23/20          Sandra Brown quoted in Wonderful LAW360 Article on Justice Ginsburg’s Legacy in Tax Cases

09/14/20          Steven Toscher, Robert Horwitz and Sandra Brown to speak on “Yes, You Actually Can Go to Jail for Not Paying Taxes” at the CPA Academy webinar on September 22, 2020

08/28/20          Sandra Brown quoted in LAW360 on IRS New Fraud Office

07/21/20          DOJ’s Tax Division Updates Criminal Tax Manual to Address Marinello’s Impact on Charging Decisions by Sandra R. Brown and Gary Markarian

07/10/20          Fifth Circuit Rules Virtual Currency Transactions and Records Held By Exchanges Do Not Have Fourth Amendment Protections from Search and Seizure by the Government by Sandra R. Brown and Tenzing Tunden

06/30/20          Sandra Brown to speak at the upcoming ABA Virtual 2020 May Tax Meeting on July 14, 2020

06/10/20          IRS Cracks Down on Tax Fraud by Creating a New Enforcement Office by Steve Toscher, Sandra Brown and Lacey Strachan

05/14/20          Dennis Perez, Michel Stein, Robert Horwitz and Sandra Brown to speak on “What Professionals Need to Know About PPP Loans and Employee Retention  Credit at the CalCPA webinar on May19 2020

05/08/20          Steven Toscher, Michel Stein and Sandra Brown to speak on “Developments in Cryptocurrency – Reporting and Enforcement” at the CPAacademy webinar on June 3, 2020

05/03/20          This May Be a Very Good Time to Consider a Voluntary Disclosure by Sandra R. Brown

05/03/20          Beware Running of Pending Statute of Limitations When Seeking Taxpayer Advocate Service Assistance – IRS Gives Notice of Nonacquiescence with Court of Appeals’ Decision that Found Seeking Help from Taxpayer Advocate Service Tolls Time to File Claim to Challenge Wrongful Levy by Sandra R. Brown

04/09/20          Taxpayer First Act and Third Party Notices – New Rules and New Interpretations to the Notice Requirements by Sandra R. Brown and Tenzing Tunden

03/28/20          Utilising the IRS Streamlined Compliance Programs to Manage US Tax Risk by Steven Toscher, Michel Stein and Sandra Brown

03/27/20          What Makes a Failure to File Your Tax Returns a Felony? by Sandra Brown

03/08/20          IRS Takes Next Step in Enhancing its Criminal Fraud Referral Program by Steven Toscher and Sandra R. Brown

01/30/20          Sandra Brown to speak at ABA Midyear Tax Meeting in Florida

01/20/20          Estate Notches Rare Win over IRS in Penalty Refund Suit by Sandra Brown and Tenzing Tunden

01/8/20            Sandra Brown quoted in Tax Analysts article on “Ride Across the Marinello Bridge Cases Could be Bumpy”

12/20/19          Revenue Procedure 2019-42: I.R.S. Provides Updated Guidance on Adequate Disclosure  by Sandra Brown and Gary Markarian

12/11/20          Steven Toscher, Dennis Perez, Michel Stein, Sandra Brown and Jonathan Kalinski to speak at USC Gould School of Law 2020 Tax Institute on January 27-29, 2020

11/28/19          Edward Robbins, Jr., Sandra Brown, Michel Stein and Evan Davis to speak at the 36th Annual National Institute on Criminal Tax Fraud in Las Vegas on December 11-13, 2019

10/27/19          Sandra Brown to speak at the California Tax Bar and California Tax Policy Conference in Mission Bay on November 8, 2019

10/20/19          AOD 2019-03: :Non-Acquiescence to Tax Court Ruling Regarding the Tax Treatment of a Franchise Transfer by Sandra Brown and Gary Markarian

10/17/19          Sandra Brown to speak at the NYU 78th Institute on Federal Taxation

10/16/19          Is ‘Corporate America’ Looking at Increased Tax Enforcement? by Steven Toscher, Sandra Brown and Gary Markarian

09/23/19          California Doubles Down on Taxing the Underground Economy: What AB 1296                           Could Mean for Tax Enforcement by Sandra Brown and Tenzing Tunden

08/13/19          Sandra Brown to speak at the Cambridge 37th Annual International Symposium on Economic Crime

08/02/19          Sandra Brown to speak on “The Rise of Injunction and Disgorgement Actions Under Section 7402 of the Internal Revenue Code

07/23/19          Sandra Brown quoted in “CI Expecting More Fraud referrals From IRS Operating Divisions,” Tax Notes

07/21/19          Sandra Brown on IRS-Criminal Investigation Unit 100 Year Celebration

07/19/19          Sandra Brown quoted in Law360 on Tax Opinions by Justice Stevens

07/02/19          Steven Toscher and Sandra Brown to speak at upcoming Fourth Annual USD RJS

Law Tax Controversy Institute on July 19, 2019

06/26/19          Sandra Brown quoted in Tax Analysts Article on IRS Data Analytics

04/17/19          Sandra Brown and Evan Davis to speak on Current Developments in IRS

Criminal Tax Enforcement

03/22/19          The Future of Virtual Currency Tax Prosecutions – A Matter of When, Not If by Sandra Brown

03/08/19          Form 830 ~ The IRS Encourages Businesses to Take Advantage of the “Speed And convenience” of E-Filing Cash Transaction Reports by Sandra Brown

02/11/19          Sandra Brown to speak at the upcoming ABA 33rd Annual National Institute in White Collar Crime, Panel entitled “New Developments in Criminal Tax Enforcement” on March 6, 2019

02/10/19          Sentencing Enhancement Upheld for Accountant Convicted of Fraudulent Scheme Executed While on Probation for an Administrative Order Prohibiting Similar Conduct by Sandra R. Brown

01/20/19          Los Angeles Lawyer – A Taxing Impediment – Marinello v. United States by

Sandra Brown

11/26/18          Tax Notes – When Noncompliance With FACTA Is More Than a Civil Tax Matter by Sandra Brown

11/14/18          Sandra Brown, Speaker on Criminal Trial Practice at the Upcoming 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy

08/30/18          Please join Steven Toscher, Sandra Brown and Evan Davis for Part One of Their Three Part Webcast Series Covering the Defense of Criminal Tax Cases Presented for the Association of Federal Defense Attorneys

08/18/18          Sandra Brown quoted in Article on rotating Fraud Technical Advisors

08/02/18          Sandra Brown quoted in Article on Implications of Ninth Circuit Withdrawing Transfer Pricing Decision

05/09/18          The New Section 162(q) of the 2017Tax Cuts & Jobs Act: The Price of Confidentiality in Sexual Harassment Cases, #NoDeduction by Sandra R. Brown

04/08/18          Tax Court Limits IRS’s Time to Assess Unreported Income from Undisclosed Foreign Accounts by Sandra R. Brown

03/04/18          Sandra R. Brown First Assistant United States Attorney and the Former Acting United States Attorney for the Central District of California’s United States Attorney’s Office has Joined Our Firm as a Principal

 

Member

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

 

Court Admissions

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



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