Charles Rettig

For more than 30 years, Chuck Rettig has been with Hochman, Salkin, Rettig, Toscher & Perez, P.C. representing clients before the Internal Revenue Service, the Tax Division of the U.S. Department of Justice, before numerous state taxing authorities and in federal and state court litigation and appeals. As a strong supporter for the integrity our system of tax administration, he has long been appointed by various Federal and state taxing authorities to their Advisory Boards and has often been invited to lecture to IRS and other government representatives regarding the accountability of both government and private tax practitioners to the public as well as to our tax system. His ongoing efforts have earned him tremendous respect throughout the government and private tax practitioner communities.

Chuck Rettig has served as Chair of numerous national, state and local professional organizations, is a frequent lecturer before such professional organizations, and is a regular columnist and author in various national tax-related publications. He is a Certified Specialist both in Taxation Law and in Estate Planning, Trust & Probate Law (The State Bar of California, Board of Legal Specialization) admitted to practice law in California, Hawai'i and Arizona (inactive), specializing in Federal and state civil tax and criminal tax controversy matters and tax litigation, including tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations.

REPRESENTATIVE EXPERIENCE

On two separate occasions, Chuck Rettig headed a group of approximately 150+ private tax practitioners in discussions and negotiations with the IRS resulting in the announcement of IRS settlement initiatives bringing thousands of U.S. taxpayers into compliance and literally billions of dollars of revenue into the government. More recently, he has actively participated in numerous similar discussions regarding the offshore voluntary disclosure programs of the IRS and certain States as well as coordinating a venue for the dissemination of information to numerous taxpayer representatives and others around the world.

Mr. Rettig routinely 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. He is internationally respected for his expertise and judgment 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.

As stated in the Chambers USA: America's Leading Lawyers for Business, "According to peers, Charles Rettig of Hochman Salkin Rettig Toscher & Perez is 'phenomenal, just phenomenal.' Further, he "is regarded by market sources as a 'brilliant and gifted lawyer . . . a real star and a national leader'" who "enjoys a superb reputation and benefits from 'great presence.'" Chambers USA has further stated "Fantastic controversy tax lawyer" Charles Rettig is "knowledgeable and very intelligent . . .a force to be reckoned with . . .a driving force in policy making at the national level with great client skills when it comes to sensitive matters."

Throughout his career, Mr. Rettig has represented thousands of individual, business and corporate taxpayers involved in civil examinations and tax collection matters as well as criminal tax investigations at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, the Court of Federal Claims and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayer's and their advisors throughout the world.

Pepperdine University
Juris Doctorate,

Avram Salkin

Avram Salkin a founding member of the firm, is recognized for his unparalled excellence and integrity in the practice of tax law. He has over fifty years of extensive experience in resolving complex Federal and state tax controversies and disputes, in structuring and negotiating complex transactional matters (including the acquisition and disposition of real estate and businesses), family wealth planning, estate planning and probate. Avram Salkin is a Certified Specialist in both Taxation and Estate Planning, Trust and Probate Law, by the The State Bar of California Board of Legal Specialization.

Recognizing a lifetime of achievements and contributions to the field of taxation, in 2003 the Taxation Section of the Los Angeles County Bar Association bestowed it's highest honor on Avram Salkin, the Dana Latham Award. In 2007 Mr.Salkin was the recipient of the Joanne M. Garvey Award given by the Taxation Section of the State Bar of California for lifetime excellence in the practice of tax law. Mr. Salkin is a Member of the Board of Governor's for the Beverly Hills Bar Association and is the Vice-Chair for the Tax Advisory Commission for the California State Bar Board of Legal Specialization. He is a Past-Chair of both the Business Law Section and the Taxation Section of the Beverly Hills Bar Association and has served on the Executive Committee of the Taxation Section of the Los Angeles County Bar Association. Previously, he served as the Tax Articles Editor of the Los Angeles Lawyer and the Los Angeles County Bar Journal.

Avram Salkin's many lectures include presentations at the ABA Section of Taxation, the University of Southern California Institute on Federal Taxation; California CPA Education Foundation Conferences (Member, Planning Committee, Pass-Thru Entities Conference); the Los Angeles County and Beverly Hills Bar Associations; programs by the California Continuing Education of the Bar on real estate taxation, professional corporations, partnership taxation, and tax procedure; and the California State University Continuing Education Program in real estate taxation. He has also written extensively on many tax-related subjects, including real estate taxation, S corporations, operating loss carryovers, employment tax issues, attorney-client privilege matters, and partnership tax issues.

Mr. Salkin is admitted to practice before the U.S. Tax Court, the U.S. District Court for the Central District of California, the United States Court of Appeals for the Ninth and Fifth Circuits, and the U.S. Supreme Court. He received his undergraduate degree, with honors in accounting, from the University of California at Los Angeles and his law degree from the University of California, Berkeley. Avram Salkin holds an "A-V" rating from Martindale-Hubbell and is often referred to as "The Tax Lawyer's Tax Lawyer."

Avram Salkin's community activities include serving as Chair of the Board of Trustees of Winward School and serving on the Board of Directors of the Guardians of the Jewish Home for The Aging and American Friends of Tel Aviv University.

Steven Toscher

PRACTICE SPECIALTY

Steven Toscher is a principal of Hochman, Salkin, Rettig, Toscher & Perez, P.C., specializing in civil and criminal tax litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization. He maintains an active practice before the United States Tax Court, the Federal District Courts in California and Nevada, the Ninth Circuit Court of Appeals and the California State Courts. He frequently appears before the Internal Revenue Service, the California Franchise Tax Board and the California State Board of Equalization. Mr. Toscher's tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, excise taxes, sales taxes and property taxes. In 1993, California Law Business Management named Mr. Toscher one of the "Up and Coming Tax Litigators under 40" in the State of California. In 2004 Mr. Toscher was named one of Southern California's Top Lawyers by SuperLawyers.com. Mr. Toscher was selected by his peers to be included in the 2006 edition of "The Best Lawyers in America." He has received an "A-V" rating from Martindale-Hubbell.

Mr. Toscher has been actively involved in California unitary tax controversies and Federal and State employment tax controversies involving garment workers; health care workers; insurance salesmen; financial services representatives; real estate personnel and production employees.

He has handled extensive tax litigation involving government securities; wind and solar energy; horse racing and breeding; equipment leasing; motion picture transactions; oil and gas and other natural resource ventures.

Reported decisions in which Mr. Toscher acted as lead trial counsel include: Addis v. Commissioner, 374 F.3d 881 (9th Cir. 2004) (split-dollar life insurance); Hoffman v. Commissioner, 119 T.C. 140 (2002) (collection due process/statute of limitations); United States v. McKoy, 78 F.3d 446 (9th Cir. 1996) (Jenks Act; Double Jeopardy); Purcell v. United States, 1 F.3d 932 (9th Cir. 1993) (IRC Section 6672); 85 Gorgonio Wind Generating Co. v. Commissioner, T.C. Memo 1994-544 (wind energy credit); Costello v. United States, 765 F.Supp. 1003 (C.D. Calif. 1991) (case of first impression involving statute of limitations and injunctive relief in TEFRA partnership proceedings); Hodgdon v. Commissioner, 98 T.C. 424 (1992) (bargain sale rules); Robertson v. Commissioner, T.C. Memo 1992-32 (innocent spouse); A. Ross Winans Grantor Trust v. Commissioner, T.C. Memo 1989-653 (horse breeding).

In addition to his civil tax practice, Mr. Toscher has an active practice in the criminal tax field, representing clients in the Federal and State courts, grand jury proceedings and before the Internal Revenue Service Criminal Investigation Division and Department of Justice Tax Division.

EDUCATION

Mr. Toscher received his Juris Doctor degree from the University of San Diego in 1979 where he graduated number one in his class receiving the designation of Summa Cum Laude. He received his undergraduate degree in accounting from the University of Nevada, Las Vegas, where he graduated with honors.

PRIOR LEGAL EXPERIENCE

Prior to joining the Firm, Mr. Toscher was a partner in Finley, Kumble, Wagner, Heine, Underberg, Manley, Myerson & Casey, responsible for Finley Kumble's West Coast tax litigation practice. While with Finley Kumble, Mr. Toscher served as Special Tax Litigation Counsel for the Securities and Exchange Commission court appointed receiver in Securities and Exchange Commission v. Elmas Trading Corp., et al., Case No. CV-R-85-263-ECR (D. Nev).

Prior to joining Finley Kumble in 1983, Mr. Toscher was a Trial Attorney with the Tax Division of the United States Department of Justice, representing the United States in tax litigation matters. Mr. Toscher was co-lead counsel in the first tax shelter injunction case brought by the Attorney General pursuant to Section 7408 of the Internal Revenue Code. United States v. Packaging Industries Group, Inc., No. 83-2307N (D. Mass. 1983) (consent decree). Mr. Toscher received a special commendation from the Department of Justice for the successful prosecution of the matter. In 1982, Mr. Toscher was the recipient of the United States Department of Justice Outstanding Attorney Award.

University of San Diego
Juris Doctorate, 1979

Dennis L. Perez

Dennis 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.

Mr. Perez, a former senior trial attorney with IRS District Counsel in Los Angeles, CA, has extensive experience in the representation of clients in civil and criminal tax litigation and in 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. He is 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. 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).

Edward M. Robbins, Jr.

Practice: Representation includes Federal and California civil tax and criminal tax litigation together with civil tax and criminal tax controversy matters before the Internal Revenue Service, the California Franchise Tax Board, the California State Board of Equalization, California Employment Development Department and various state taxing authorities of individuals, business enterprises, partnerships, limited liability companies, and corporations. Representation also includes individuals and organizations involved as targets, subjects, or witnesses in Federal and California criminal investigations and related grand jury and pre-trial proceedings, trials and appeals.

As Chief of the Tax Division, Central District of California's United States Attorney's Office, Edward M. Robbins, Jr., handled a full caseload specializing in complex civil and criminal tax litigation. In addition to his litigation duties he was responsible for the management and coordination of the Tax Division's tax cases and supervised the Special AUSA's in bankruptcy matters and worked with the Assistant Attorney General (Tax) to develop and ensure uniform national tax policy.

Mr. Robbins has represented the government at the trial level in hundreds of significant and complex civil and criminal tax cases, including United States v. Galletti, ___U.S.___ (2004) (assessment against partnership valid against unassessed general partner); United States v. Brockamp, 519 U.S. 347 (1997)(no equitable tolling of tax refund claim statute of limitations); United States v. Williams, 514 U.S. 527 (1995)(defining "taxpayer"); United States v. Carlton, 512 U.S. 26 (1994)(retroactive tax statute valid); Church of Scientology of California v. United States, 506 U.S. 9 (1992)(summons enforcement jurisdiction); United States v. Schulman, 817 F.2d 1355 (9th Cir. 1987)(criminal tax fraud).

University of San Diego
LL.M., 1984

Sharyn M. Fisk

Sharyn Fisk specializes in civil tax and criminal tax controversy, trust and estate planning, and probate. Ms. Fisk earned her J.D. from Rutgers University School of LawNewark and her LL.M in Taxation from New York University School of Law. She worked as an Attorney-Advisor for the Honorable Maurice B. Foley, United States Tax Court. Ms. Fisk is also a Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization.

1. Ms. Fisk is a member of the Executive Committee for the Taxation Section, State Bar of California; Secretary of the Taxation Procedure Committee of the Taxation Section, Los Angeles County Bar Association; a member of the Standards of Tax Practice Committee of the Taxation Section, American Bar Association; a member of the Taxation Section, Beverly Hills Bar Association; and a member of American Mensa, Ltd.
Ms. Fisk coauthors a quarterly update on Important Civil Tax Controversy Developments for the ABA Section of Taxation. In addition, she coauthored Important Developments During the Year Civil Tax Penalties, The Tax Lawyer, Summer 2003, and Current IRS Enforcement Issues for the Coming Year, 56th USC Tax Institute (Matthew Bender). Ms. Fisk Chaired the "Task Force on Registration of Unenrolled Return Preparers" for the Standards of Tax Practice Committee of the ABA Section of Taxation and has lectured before the ABA Section of Taxation on Important Civil Tax Controversy Developments. Ms. Fisk is an Adjunct Professor for Chapman Law School's LL.M Taxation program and for the Graduate Tax Program at Golden Gate University.

Ms. Fisk is admitted to practice before the U.S. Tax Court, the U.S. District Court for the Central and Southern Districts of California, the U.S. Court of Claims, and the U.S. Court of Appeals for the Ninth Circuit.

Rutgers University School of Law
Juris Doctorate,

Michael R. Stein

MICHEL R. STEIN is a principal at Hochman, Salkin, Rettig, Toscher & Perez, specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. He also has extensive expertise in trust & estate planning, and business transactions. Mr. Stein graduated from the University of California, Hastings College of the Law and received his LL.M. in Taxation from the NYU School of Law. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court. He is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization.

Mr. Stein has published extensively in the field of tax law. He has authored "FBAR Examination, Appeals and Collection Procedures in the Post-Amnesty World," appearing in the January 2012 edition of CCH Journal of Tax Practice and Procedure. Mr. Stein has contributed insight and analysis to the CCH (a Wolters Kluwer Business) publication "2010 Tax Legislation, Patient Protection and Affordable Care, Health Care Reconciliation, HIRE and Other Recent Tax Acts", Law, Explanation, and Analysis. Mr. Stein co-authored a chapter in the USC Gould School of Law's 2009 Major Tax Planning Edition, "Foreign Bank Secrecy No More A New Era of International Tax Enforcement as well as "FBAR Enforcement Five Years Later," appearing in the July 2008 edition of CCH Journal of Tax Practice and Procedure and "FBAR An Update," appearing in the May 2006 edition of CCH Journal of Tax Practice and Procedure, and "Criminal Enforcement of FBAR Filing Requirements," found in the June 2006, Law Journal Newsletters, Business Crime Bulletin. He has also authored "The Continuing Debate of Multi-disciplinary Practices," appearing in the November 1999 edition of Los Angeles Lawyer Magazine, and co-authored "FBAR Enforcement is Coming!," which was published in the January 2004 edition of CCH Journal of Tax Practice and Procedure.

NYU School of Law
LL.M.,

Kurt Kawafuchi

Kurt Kawafuchi specializes in tax controversies as well as tax, business, charitable and estate planning, and family wealth transfers. His representation includes Federal and state civil and criminal tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. Kurt is a frequent lecturer before national, state and local professional organizations and has authored articles in many national, state and local publications.

Kurt Kawafuchi was appointed by the Governor of Hawai'i and served as the Director of the Department of Taxation from 2002 to 2010. In this position, he was responsible for all aspects of tax administration for the state of Hawai'i, including audits, collections, criminal tax investigations, legislation, administrative guidance, operations, taxpayer services and research and planning.

Prior to his appointment as Director of the Department of Taxation, Kurt supervised the Attorney General's Tax Division for the State of Hawai'i, which represented the state in tax litigation in all federal and state trial and appellate courts, and acts as parens patriae in supervising charities and nonprofits. Prior to November 1999, Kurt practiced law at Goodsill Anderson Quinn & Stifel in Hawai'i. His practice focused on tax law, international and domestic business and estate planning, and representing clients in civil and criminal tax controversies and litigation. From 1986 to 1992, Kurt was a trial attorney with the U.S. Department of Justice, Tax Division, Washington, D.C., and represented the Internal Revenue Service in federal and state courts in Hawai`i and California.

Cory Stigile

Cory Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state civil and criminal tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations.

Cory Stigile is also a Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization.

Mr. Stigile frequently writes and lectures on topics involving taxation. His more recent speaking engagements include an "Income Tax Update" for California State University, Los Angeles, "Tax Identity Theft" for the Taxation Technical Committee of the Los Angeles Chapter of CalCPA, and the "IRS Audit Programs and Other Hot Tax Controversy Issues" for the Santa Clarita Valley Discussion Group of the Los Angeles Chapter of CalCPA. Mr. Stigile was awarded the distinction of Super Lawyer Rising Star in 2012, as recognized and published in Los Angeles Magazine. He is also on the Planning Committee of the Annual UCLA Extension Tax Controversy Institute.



In addition to being a licensed lawyer, Mr. Stigile is also a CPA licensed in California. He is currently the President of the Los Angeles Chapter of CalCPA.

His civic activities have included volunteer work with the Community Tax Aid of New York (2005), the Volunteer Income Tax Assistance Program at California Lutheran University (1997-1998), The Los Angeles Young Lawyers Association (current), and The Special Olympics in New York City. He was also the Race Director for the annual CalCPA Brentwood 5K/10K run during 2008 and 2009.

New York University
LL.M.,

Lacey Strachan

Lacey Strachan's representation includes civil and criminal tax controversies as well including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. Her representation also includes tax, business, charitable and estate planning, and family wealth transfers.

Education:

New York University (LL.M. in Taxation)

University of Southern California Law School (J.D.), Order of the Coif; Deloitte Award (for excellence in Corporate Taxation), Journal: Southern California Law Review, Senior Content Editor

University of California, Los Angeles (B.A., Business Economics), Phi Beta Kappa, magna cum laude; College Honors

Memberships:

American Bar Association

Section of Taxation

Young Lawyers Division

California State Bar Association

Taxation Section

Tax Procedure and Litigation Committee

Los Angeles Westside Young Tax Lawyers Committee

Los Angeles County Bar Association

Taxation Section

Beverly Hills Bar Association

Bar Admittance:

U.S. Court of Appeals, Ninth Circuit

U.S. District Court, Central, Eastern, Northern and Southern Districts of California

U.S. Tax Court

Supreme Court of California

New York University
LL.M.,