Continuing Impact of Notable Tax Cases: Applying Landmark Tax Decisions to Current Tax Matters

Mr. Davis joined the firm in 2016 after more than 20 years in the public sector as a trial lawyer with extensive civil and criminal trial and appellate experience in both federal and state courts. He and his cases have been profiled by the New York Times, Wall Street Journal, Los Angeles Times, People Magazine, as well as national legal publications such as Tax Notes and Law360.  Mr. Davis represents individuals and closely held entities in criminal tax investigations and prosecutions, civil tax controversy and litigation, sensitive-issue or complex civil tax examinations and administrative tax appeals, and federal and state white-collar criminal investigations. He represents numerous cryptocurrency clients worldwide on civil and criminal tax matters, speaks frequently on cryptocurrency, criminal tax, and Bank Secrecy Act issues, deals with civil and criminal cannabis-related tax issues, and handles civil and criminal unreported foreign account and foreign-entities investigations and disclosures.  In the appellate arena, Mr. Davis has argued cases before the Ninth Circuit Court of Appeals as both a prosecutor and defense counsel and was trial and appellate counsel on the attorney-client privilege case In re Grand Jury, which the U.S. Supreme Court heard in 2023. Mr. Davis frequently lectures on many topics throughout the country both in the private sector and as a federal prosecutor. 

Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets and provides tax advice to taxpayers and their advisors throughout the world. He handles both federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski has considerable experience handling complex civil tax examinations, administrative appeals, and tax collection matters.  Prior to joining the firm, he served as a trial attorney with the IRS Office of Chief Counsel litigating Tax Court cases and advising revenue agents and revenue officers on a variety of complex tax matters. 

Mr. Horwitz has over 35 years of experience as a tax attorney specializing in the representation of clients in civil and criminal tax cases, including civil audits and appeals, tax collection matters, criminal investigations, administrative hearings and in civil and criminal trials and appeals in federal and state courts. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and was Chair of the Taxation Section for 2015-2016 year.  Mr. Horwitzwas previously Chair of the Tax Procedure and Litigation Committee of the State Bar Taxation Section. Prior to joining Hochman Salkin Toscher Perez P.C., Mr. Horwitz was with a boutique tax controversy firm in Orange County, where he represented clients in civil and criminal tax cases in the U.S. Courts of Appeal, U.S. district courts, California superior courts, and before the Internal Revenue Service, the California Franchise Tax Board, the Board of Equalization, the Employment Development Department and the Unemployment Insurance Appeals Board. He has been a speaker on tax matters at the UCLA Tax Controversy Institute, the Annual Meeting of the Taxation Section of the California Bar and the California State Bar Annual Meeting. Mr. Horwitz has authored articles on tax law that have appeared in diverse publications, including Tax Notes, the Federal Lawyer (the publication of the Federal Bar Association), and the California Tax Lawyer.  His monograph in “Responsible Persons and Fiduciary Liability” was published in the Proceedings of the New York University 75th Institute on Federal Taxation.  Mr. Horwitz was an invited delegate to the 2015 U.S. Tax Court Judicial Conference.  He is a member of the Planning Committee of the UCLA Tax Controversy Institute. Mr. Horwitz is a member of the bar in California and in Illinois. He is admitted to practice in the United States District Courts for the U.S. Supreme Court, the U.S. Courts of Appeal for the Seventh, Ninth and Federal Circuits, the U.S. District Courts for the Central, Southern, Northern and Eastern Districts of California, the U.S. Court of Federal Claims and the U.S. Tax Court. He was named a Southern California Super Lawyer 2010, 2011, 2012, 2014, 2015, 2016, 2017 and 2018.