Understanding the Economic Substance Doctrine

Sebastian Voth is a Principal of the law firm Hochman Salkin Toscher Perez P.C., where he specializes in tax investigations, litigation and appeals, and complex tax matters. Prior to entering private practice, Mr. Voth served for 15 years at the Internal Revenue Service including most recently as a Special Trial Attorney with the IRS Office of Chief Counsel’s Strategic Litigation Division leading trial teams in all phases of litigation before the Tax Court.

During his tenure with the IRS, Mr. Voth served on the leadership team of the nationwide IRS Counsel mentoring program and mentored numerous IRS attorneys. He is the recipient of two Lucite Awards for significant Tax Court opinions and received a 2024 Special Act Award (Strategic Litigation), the 2023 Nationwide Innovator of the Year (LB&I), the 2022 Nationwide Special Trial Attorney of the Year (SB/SE), the 2017 U.S. Department of the Treasury Outstanding Litigator and the 2017 Nationwide Attorney of the Year (SB/SE).

As a Special Trial Attorney, Mr. Voth also lectured on civil tax fraud, litigation skills, including the Federal Rules of Evidence, best practices for preparing cases for trial, and working with expert witnesses. He has also presented at various professional tax conferences including the ABA Tax Midyear Meeting, the UCLA Extension’s Annual Tax Controversy Conference and the USC Tax Institute.

Mr. Voth received his Juris Doctor degree with honors from Emory University School of Law, where he graduated the most outstanding tax student in his class. He received his undergraduate degree from Georgia State University where he completed a double major in Spanish and Political Science while being a student-athlete.