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Resolving Employment Tax Disputes


Cost Free
Presentation Length 1.0 hour

Recorded DateDecember 7, 2020
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

The IRS is increasing both civil and criminal enforcement against taxpayers who fail to comply with withholding and remitting of employment taxes. Non-compliance can cause heavy penalties and interest against taxpayers that could destabilize a company and its operations. Tax professionals and advisers must grasp a complete understanding of tax rules and available techniques to avoid or minimize tax assessments and penalties.

This webinar will guide tax professionals and advisers on critical issues relating to employment taxes. The panel will discuss essential techniques to avoid penalties and handling IRS audits stemming from employment taxes. The panel will also address worker classification issues and methods to overcome them, the impact of California AB 5, critical considerations for state versus federal compliance, the government use of injunctions, and criminal aspects of employment tax issues.  Listen as we provide practical methods to avoid or minimize trust fund recovery penalties and tactics in handling IRS examinations.

Learning Objectives: 

  • Identify how the IRS is increasing both civil and criminal enforcement against taxpayers who fail to comply with withholding and remitting of employment taxes

  • Determine how non-compliance can cause heavy penalties and interest against taxpayers that could destabilize a company and its operations

  • Recognize an understanding of tax rules and available techniques to avoid or minimize tax assessments and penalties

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MICHEL R. STEIN is a principal at Hochman, Salkin, Toscher & Perez, specializing in tax controversies and tax planning for individuals, businesses, and corporations. For almost 20 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters.

Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. Government’s ongoing enforcement efforts regarding undeclared interests in 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. He has assisted hundreds of individuals who have complied with their foreign reporting requirements through the OVDP, Streamline, or otherwise.

Throughout his career, Mr. Stein has represented thousands of individual, business, and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters, as well as with possible assertions of fraudulent conduct and in defending criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayers and their advisors around the world.

Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. Mr. Stein received his LL.M. in Taxation from the NYU School of Law and graduated from the University of California, Hastings College of the 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.


Dennis Perez has extensive experience in representing clients in civil and criminal tax litigation and tax disputes and controversies before the Internal Revenue Service and all of the California taxing agencies. Mr. Perez was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in LOS Angeles, California. Mr. Perez is a Certified Tax Specialist, California State Bar Board of Certification, and a Fellow of the American College of Tax Counsel. He frequently lectures on advanced civil and criminal tax topics at seminars and before national, state, and local bar associations and accountancy groups. He is a co-author of the BNA Portfolio, Tax Crimes, and has served as the Chair of the Los Angeles Lawyer Magazine Editorial Board, and is the first-ever recipient Of the Los Angeles Lawyer Sam Lipsman Service Award established in memory of the late publisher Sam Lipsman. He is past Chair of the Tax Procedure and Litigation Committees Of the Taxation Sections Of the State Bar Of California and the Los Angeles County Bar Association. Mr. Perez is past President of the Alumni Board for the UCLA School Of Law and has served as an Adjunct Professor, Golden Gate University, Graduate School of Taxation.


Jonathan Kalinski specializes in civil and criminal tax controversies and sensitive tax matters, including disclosures of previously undeclared interests in foreign financial accounts and assets. He 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.  Before 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 various complex tax matters.  Jonathan Kalinski also previously served as an Attorney-Adviser to the Honorable Juan F. Vasquez of the United States Tax Court.

About Our Presenter

HOCHMAN, SALKIN, TOSCHER & PEREZ, P.C., enjoys an unparalleled reputation for excellence and integrity in the tax community. For more than 60 years, the firm has been serving clients throughout the United States with federal and state civil tax litigation, defense of criminal tax prosecutions, all forms of tax disputes with the federal, state and local taxing authorities, white collar criminal defense, estate and business planning, and business transactions.