Refund Litigation – Where District Court differs from Tax Court

Melissa Briggs is a Principal of the law firm Hochman Salkin Toscher Perez P.C., where she specializes in tax investigations, litigation and civil tax matters.  Ms. Briggs has over 20 years of litigation experience in private, nonprofit, and government practice.  Ms. Briggs served a combined 16 years as an appellate attorney for the U.S. Department of Justice, Tax Division Appellate Section and, most recently, as an Assistant United States Attorney with the United States Attorney’s Office for the Central District of California’s Tax Division.

During her tenure with the U.S Attorney’s Office, Ms. Briggs handled all aspects of litigation of affirmative and defensive civil tax cases in the United States District Court for the Central District of California, United States Bankruptcy Court for the Central District of California, and California state courts.  She served as a Federal Women’s Special Emphasis Programs Manager coordinating office-wide events including panel discussions and networking events.

Ms. Briggs has briefed and argued both civil and criminal tax appeals.  As a Tax Division appellate attorney, she served as lead appellate counsel in over 100 civil cases appealed from the United States District Courts, Tax Court and Court of Federal Claims in all 13 United States Courts of Appeals.  Ms. Briggs served as a law clerk to the Honorable Phyllis A. Kravitch on the United States Court of Appeals for the 11th Circuit.

Ms. Briggs is the recipient of the U.S. Department of Justice, Tax Division, Outstanding Attorney Award and the Alabama State Bar Pro Bono Award.

Gary M. Slavett has been a California licensed attorney since 1996 and has over 20 years of experience in the practice of tax law. Gary’s practice focuses on tax controversy matters including issues related to Foreign Bank Accounts & FBAR penalties, criminal tax defense, tax litigation, tax audit representation, and tax administrative appeals. Gary also handles matters related to the Bank Secrecy Act and Administrative and Civil Forfeitures. Gary frequently represents his clients before the United States Tax Court, U.S. District Court, Internal Revenue Service, United States Attorneys Office, California Franchise Tax Board, State Board of Equalization, and the Employment Development Department. Gary was a Senior Trial Attorney for the Internal Revenue Service, Office of Chief Counsel. As an IRS attorney, Gary represented the IRS in U.S. Tax Court and provided legal advice to IRS personnel. After leaving the IRS, Gary joined Deloitte & Touche’s Tax Controversy Group in Los Angeles. At Deloitte, Gary represented Deloitte’s clients before the IRS and state taxing authorities. Clients included Fortune 500 companies from the banking, healthcare, and toy industries, a professional sports team, a popular television personality, and regional real estate and construction firms.