Estate and gift tax controversy matters have unique procedures and issues that differ from income tax examinations. Knowing the differences can be crucial when dealing with the IRS. In this presentation, Richard will examine some of the unique aspects and issues related to estate and gift tax controversy matters.

Richard Gano is a tax attorney with Holtz, Slavett, & Drabkin. Richard practices in all types of tax controversy matters including income tax, estate tax, gift tax, employment tax, collection issues, and penalties. He represents clients in tax audits, collection defense, and litigation before the Internal Revenue Service, California Franchise Tax Board, Department of Fee and Tax Administration (formerly State Board of Equalization), Employment Development Department, and in the U.S. Tax Court and federal district court. Richard received his J.D. and LL.M. in Taxation from Loyola Law School in Los Angeles. While at Loyola, he was a technical editor on the Loyola of Los Angeles Law Review, published an article on the tax consequences of egg donation, and was the President of Loyola’s Tax Law Society. He received his B.S., magna cum laude, in Accountancy from California State University Northridge and passed all of the CPA exams.

If you have questions about estate and gift tax controversy matters, you can reach out to Richard at rgano@hsdwtaxlaw.com or 310-550-6200. Richard is a former IRS Counsel attorney who has extensive experience in navigating these and many other tax controversy related issues.

Attorneys can often find themselves in murky situations regarding their ethical duties when they represent multiple clients that appear to have aligned interests at the beginning of an engagement. This can arise in matters involving closely held businesses and their shareholders, partnerships and partners, and trusts, their trustees, and their beneficiaries. Analyzing the ABA Model Rules, the panel will analyze when conflicting and adverse interests between clients can be represented by the same lawyer, when instituting a wall between lawyers in the same firm can be sufficient, and conflicts rise to the point where the attorney can no longer represent all the parties involved in the matter.

The panel will also discuss ethical considerations surrounding the use of artificial intelligence (AI). Attorneys have increasingly been using AI to conduct legal research and draft legal documents. The panel will explore an attorney’s duties and responsibilities in using AI generated work product, particularly when filing those work products in court.

If you have questions about client conflicts of interest, you can reach out to Michele at mweiss@hsdwtaxlaw.com or 310-550-6200. Michele is a former IRS Counsel attorney who has extensive experience in navigating these and many other tax controversy related issues.

The IRS is focusing on S corporations as one of the main ways to increase tax compliance and lower the tax gap. The IRS is especially interested in issues surrounding shareholder basis, taxable distributions, and losses. In this presentation, David will discuss the IRS’s focus on S corporations, the rules for distributions and deductibility of losses, IRS Form 7203, and how to navigate through these complex audits. To register for this webinar, please click here.

David J. Warner practices in all aspects of tax controversy including tax audits, collection defense, and tax litigation. Before joining Holtz, Slavett, Drabkin & Warner, David was a Senior Trial Attorney with the IRS Office of Chief Counsel in Laguna Niguel, California for 9 years. As an IRS attorney, he handled over 500 cases before the U.S. Tax Court, including the most complex cases involving S corporations and partnerships. As is relevant to this presentation, David was a founding member of the IRS Southwest Area Partnership Cadre that advised IRS revenue agents on audits involving S corporation issues, and David also trained hundreds of IRS lawyers on S corporation tax issues. David was an Adjunct Professor of Law at University of California Irvine School of Law, Chapman University Fowler School of Law, and Loyola Law School, where he taught courses on tax practice and procedure, partnership tax, bankruptcy tax, and corporate tax (including the taxation of S corporations).

Holtz, Slavett, Drabkin & Warner, APLC is a tax controversy and tax litigation law firm consisting of former IRS trial attorneys. We represent taxpayers in all aspects of tax disputes with the IRS and state tax authorities, including IRS audits. To schedule a consultation with David, please contact us at (949) 999-6606.

Holtz, Slavett, Drabkin & Warner, APLC is very proud to announce that four of our principals were named as 2026 Southern California Super Lawyers in Tax Law.  David Holtz, Gary Slavett, Igor Drabkin and Michele Weiss were recognized among the best tax attorneys who have achieved a high degree of professional achievement and peer recognition. In addition, Richard Gano and Kevin Oveisi were named as Rising Stars in the field of law in the same 2026 Super Lawyers edition.

Each year, no more than 5 percent of the lawyers in the region are selected by the research team at Super Lawyers to receive this honor.  Super Lawyers selects attorneys using peer nominations and evaluations combined with independent research. Each candidate is evaluated on 12 indicators of peer recognition and professional achievement, and selections are made on an annual, state-by-state basis. We’re honored that David, Gary, Igor, Michele, Richard and Kevin were recognized as best of the best tax lawyers!

In a fireside chat format, Michele will lead the panelists to discuss settlement procedures for the FTB and CDTFA. The panelists will explore and explain best practices and timing for taxpayers to request settlement for their tax disputes. The panelists will provide insights and practical tips for practitioners who represent taxpayers in California income, sales tax, and other California tax disputes, from the perspective of the FTB and CDTFA.

If you want additional information about settlement options for California tax disputes, you can reach out to Michele at mweiss@hsdwtaxlaw.com and 310-550-6200. Michele has over 25 years of experience handling federal, state, and local tax disputes.

Michele, Sebastian and Jimeel will discuss valuation issues in transfer pricing, estate and gift matters, and non-cash charitable contributions. They will analyze lessons learned from tax opinions involving valuation issues. They will also give practical tips on working with experts including handling communications with experts, privilege issues, motions in limine to exclude experts, and  working with experts at trial.

Michele has extensive experience working with experts in tax matters both during administrative proceedings and at trial. If you have questions about working with experts in a tax matter, you can contact Michele at  mweiss@hsdwtaxlaw.com or 310-550-6200. Michele is a former IRS Counsel attorney with over 25 years of experience in tax controversy matters including audits, litigation, and collection matters with federal, state, and local taxing authorities.

Holtz, Slavett, Drabkin & Warner,  A Professional Law Corporation

Holtz, Slavett, Drabkin & Warner, APLC is a tax controversy and tax litigation law firm consisting of former IRS attorneys.  For the past 20 years, our firm has helped thousands of clients resolve issues with the Internal Revenue Service and state tax agencies, including audits, administrative appeals, tax litigation, criminal tax, and tax collection defense.  Our firm has nine former IRS attorneys who have significant trial and administrative experience both inside and outside the government, which gives our firm a comprehensive understanding of the internal workings of governmental tax agencies.  Our attorneys have the highest level of educational and professional tax backgrounds, including Tax LL.M.s from leading law schools, experience with big four accounting firms, and expertise as tax professors.

To schedule a consultation, please contact us at (310) 550-6200 (Los Angeles office) or (949) 999-6606 (Orange County office).  You can visit our website at www.hsdwtaxlaw.com to learn more about our firm.

The panel will explore how recent opinions including Loper Bright and Jarkesy offer new avenues for taxpayers to explore when pursuing their tax cases. Moreover, the panel will explain how taxpayers can challenge “normal” courses of action in their tax cases to find new and better ways to succeed in their tax disputes.

For more information on how to navigate success in tax disputes, you can contact Michele at 310-550-6200 x16 or mweiss@hsdwtaxlaw.com.

FBAR remains a complicated reporting obligation and the IRS will cross-reference FBAR information with other tax filings, as well as information disclosures from other sources such as foreign financial institutions. This makes failure to accurately report assets on the FBAR potentially very costly for U.S. taxpayers, even with the extension provisions of the new regulations.

The program will discuss the FBAR filing requirements, potential willful and non-willful penalties, procedures for dealing with the FBAR issues and penalties, and provide update on the new enforcement and court developments.

Igor Drabkin is a principal at Holtz, Slavett, Drabkin & Warner and a California State Bar Certified Tax Law Specialist. A former Senior Trial Attorney with the IRS and Special Assistant U.S. Attorney, Igor has extensive experience handling complex tax controversies, audits, criminal investigations, and international tax enforcement. He has litigated cases in federal, state, and bankruptcy courts and frequently speaks on tax litigation, FBAR penalties, and procedural issues. A former adjunct professor at Golden Gate University’s Graduate School of Taxation, Igor brings both practical and academic insight to his continuing education courses. Igor received his Juris Doctor degree, cum laude, from Pepperdine University School of Law. Igor received his Bachelor’s degree in Finance from the California State University, Northridge. Igor is fluent in Russian.

Kevin Oveisi is a former IRS Senior Trial Attorney who has experience practicing in all aspects of tax controversy including income tax, estate tax, gift tax, employment tax, collection issues, penalties, and litigation in the U.S. Tax.  Court.  At the IRS, Kevin was a Senior Trial Attorney with the IRS Office of Chief Counsel, Small Business Self-Employed Division, in Manhattan and Laguna Niguel.  As an IRS attorney, he represented the IRS in over 400 cases before the U.S. Tax Court, including the most complex cases.

Holtz, Slavett, Drabkin & Warner, APLC is a tax controversy and tax litigation law firm consisting of former IRS trial attorneys.  We represent taxpayers in all aspects of tax disputes with the IRS and state tax authorities.  To schedule a consultation, please contact us at (949) 999-6606.

The panel will cover practical insights on navigating IRS examinations, responding to notices and summonses, pursuing administrative remedies, and litigating in the U.S. Tax Court, U.S. District Courts, and the Court of Federal Claims.

Kevin Oveisi is a former IRS Senior Trial Attorney who has experience practicing in all aspects of tax controversy including income tax, estate tax, gift tax, employment tax, collection issues, penalties, and litigation in the U.S. Tax.  Court.  At the IRS, Kevin was a Senior Trial Attorney with the IRS Office of Chief Counsel, Small Business Self-Employed Division, in Manhattan and Laguna Niguel.  As an IRS attorney, he represented the IRS in over 400 cases before the U.S. Tax Court, including the most complex cases.

Holtz, Slavett, Drabkin & Warner, APLC is a tax controversy and tax litigation law firm consisting of former IRS trial attorneys.  We represent taxpayers in all aspects of tax disputes with the IRS and state tax authorities.  To schedule a consultation, please contact us at (949) 999-6606.