USC Gould School of Law 2025 Tax Institute – A Look Back at Our Attorneys


We are pleased to announce that the USC Gould School of Law 2025 Tax Institute was a great success this year carrying on a long tradition in Los Angeles. We were fortunate to have our lawyers (including Jonathan Kalinski not pictured) lead great discussions on some of the most important issues in tax controversy.
Thank you to all the panel members.

“It was my honor to moderate a panel on Employee Retention Credits with my fellow tax experts, Dan Mayo and Philip Wilson, at the USC Gould School of Law 2025 Tax Institute.“

“A shout out to our expert panel for an informative and valuable discussion at the USC Tax Institute on the topic of The IRS New Focus on Subchapter K Enforcement, including the Use of the Economic Substance Doctrine – What Does it Mean for Tax Practitioners. The panel moderated by Michel R. Stein, who joined with 𝗛𝗮𝗻𝘀 𝗙𝗮𝗺𝘂𝗹𝗮𝗿𝗼, IRS Special Counsel and Aaron Vaughan, Managing Director of KPMP, to provide an in-depth perspective on partnership enforcement , the new IRS Basis Shifting Regulations, and the Economic Substance Doctrine.”

“The speakers on this panel, which included an experienced IRS lawyer, reaffirmed that the IRS cares about fraud and will continue to pursue civil and criminal fraud cases.”
Sandra R. Brown is a Principal of the law firm Hochman Salkin Toscher Perez P.C., where she specializes in criminal tax investigations, grand jury matters, litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals, as well as civil litigation. Prior to joining the firm, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney; and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California.
During her 27 years as a trial lawyer, she personally handled over 2,000 tax cases on behalf of the United States. During her tenure with the government, Ms. Brown 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, the highest recognitions awarded by the IRS to non-IRS employees.
Ms. Brown obtained her LL.M. in Taxation from the University of Denver, is a fellow of the American College of Tax Counsel, Vice-Chair of the ABA’s Section of Taxation’s Criminal and Civil Tax Penalties Committee, Co-Chair of the UCLA Tax Controversy Institute, Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference, an ABA Loretta Collins Argrett Fellowship Mentor, and is a frequent lecturer and author on tax controversy topics, including international compliance matters. Ms. Brown has been recognized as one of California’s top 100 leading women lawyers and most recently, the recipient of USD School of Law’s Richard Carpenter Excellence in Tax Award and honored at the California Lawyers Association Tax Bar and Tax Policy 2024 Toast to Women in Tax.
For more information, please contact Sandra Brown at brown@taxlitigator.com
Michel R. Stein is a Principal at Hochman Salkin Toscher Perez P.C., specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil and criminal tax matters where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance tax matters. Mr. Stein is a frequent lecturer at national and regional conferences on topics, including Global High Wealth examinations, cryptocurrency, sensitive tax compliance matters, IRS examinations, International tax issues and state and federal residency and worker classification matters.
For more information, please contact Michel Stein at stein@taxlitigator.com
Evan Davis has been a Principal at Hochman Salkin Toscher Perez P.C. since November 2016. He spent 7.5 years as a DOJ Tax civil litigator and then 11 years as an AUSA in the Office of the U.S. Attorney (C.D. Cal), including 3 years handling civil and criminal tax cases and 8 years as a white-collar prosecutor handling tax and other fraud cases from investigation through jury trial and appeal. As an AUSA, he served as the Bankruptcy Fraud coordinator, Financial Institution Fraud coordinator, and Securities Fraud coordinator. Mr. Davis handles federal and state criminal and civil tax investigations/exams, white-collar defense, cryptocurrency clients, and civil and criminal appellate matters including having litigated the In re Grand Jury attorney-client privilege matter before the US Supreme Court in 2023.
For more information please contact Evan Davis at davis@taxlitigator.com