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Our Firm Dennis L. Perez

perez@taxlitigator.com Phone: (310) 281-3200
Fax: (310) 859-5106 Download Vcard

Dennis L. Perez represents and advises clients in foreign and domestic civil tax examinations and administrative appeals where substantial civil income tax and penalty issues may arise, and he has extensive experience in representing clients in criminal tax fraud investigations and prosecutions. He also represents clients in the U.S. Tax Court and in all federal trial and appellate courts. These are matters before the Internal Revenue Service, Chief Counsel, IRS, and the Department of Justice, Tax Division. Mr. Perez is highly respected for his calm demeanor, judgment and extensive experience in the handling of matters arising from the U.S. government’s ongoing enforcement efforts in a variety of civil tax scenarios, including voluntary disclosures and dealing with taxing authority agents to minimize potential exposure to civil tax penalties and avoiding referrals to Criminal Investigation.

Mr. Perez also represents entities and individuals before the California Franchise Tax Board, Employment Development Department and Department of Tax and Fee Administration on a variety of income tax, business tax, employment tax and sales tax issues.  He also provides advisory and representation services on California residency and domicile issues.

Mr. Perez, a former senior trial attorney with IRS District Counsel in Los Angeles, CA. He is a member of the Planning Committee of the UCLA Extension Annual Tax Controversy Institute and is also a Certified Specialist, Taxation Law, State Bar of California, Board of Legal Specialization, and a fellow of the American College of Tax Counsel.

Mr. Perez frequently lectures on advanced substantive and procedural tax topics at various seminars and before state and local bar associations and professional accounting groups. He was instrumental in the creation of the United States Tax Court “Pro Se Video” sponsored by the Taxation Section of the State Bar of California. Also, as part of a delegation of California tax attorneys, he proposed an experimental Settlement Judge Procedure to the United States Tax Court. Mr. Perez is the first ever recipient of the Los Angeles Lawyer Sam Lipsman Service Award. This award was established in memory of the late publisher, Sam Lipsman, to honor an Editorial Board member who has provided exemplary service on behalf of Los Angeles Lawyer.  Dennis Perez is a past Vice-Chair of the Executive Committee of the Taxation Section of the State Bar of California and the Past-Chair of the Tax Procedure and Litigation Subcommittees of both the Taxation Section for the State Bar of California and the Los Angeles County Bar Association and he is the Past-Chair of the Los Angeles Lawyer Magazine, the magazine for the Los Angeles County Bar Association. Mr. Perez is Past-President of the UCLA Law School Alumni Board and lecturer for the UCLA School of Law, USC Marshall School of Business, and was an Adjunct Professor, Golden Gate University, Graduate School of Taxation.

Presentations:

  • October, 2023 – CalCPA – Office of Tax Administration: Handling a Case Before California OTA
  • October, 2023 – 39th Annual UCLA Tax Controversy Institute – Employee Retention Credits – Promoters, (Ghost) Preparers and the Employers Caught in the Middle
  • June, 2023 – CPA Academy – Resolving Employment Tax Disputes
  • October, 2022 – UCLA 38th Annual Tax Controversy Institute – R&D Credits: “If You Build It, They Will Come . . . The Taxing Authorities Focus on R&D Credits.
  • September, 2022 – Spidell – Research and Development Tax Credits: IRS Scrutiny of Qualified Research Activity and Related Expenses
  • August, 2022 – CalCPA – Office of Tax Administration: Handling a case before California OTA
  • June, 2022 – Strafford – Research and Development Tax Credits: IRS Scrutiny of Qualified Research Activity and Related Expenses
  • May, 2022 – Strafford -Federal and State Residency issues: Remote Workers and navigating IRS Examination Guidance and State Regulations in the Post-Covid-19 World
  • May, 2022 – CalCPA – Research and Development Tax Credits: IRS Scrutiny of Qualified Research Activity and Related Expenses
  • January, 2022 – USC Tax Institute – Tips on Trying a Civil Tax Fraud Case
  • November, 2021 – Motion Picture and Television Fund – The California Exodus: How to Exit the State with Your Fortune Intact (or Not)
  • October, 2021 – CalCPA – Advising High Income Non-Filers, Voluntary Disclosure and Collection Issues
  • October, 2021 – UCLA 37th Annual Tax Controversy Institute – Employment Tax Enforcement: How AB-5 Has Changed the Employment Tax World
  • August, 2021 – CalCPA – Employment Tax Matters: Worker Classification and AB5
  • January, 2021 – USC Annual Tax Institute – Representing the High-Income Non-filer in the New Non-filer Enforcement Environment
  • November-December, 2020, January, 2021 – CalCPA – Federal Practice and Procedures Update
  • October, 2020 – Strafford – High Income Non-Filers, Voluntary Disclosures and IRS Collection Issues: Enforcement Actions, Penalties, Compliance
  • October, 2020 – Spidell – High Net Worth Audits
  • October, 2020 – UCLA 36th Annual Tax Controversy Institute – Employment Tax Enforcement – How AB 5 Has Changed the Employment Tax World
  • July, 2020 – CPA Academy – Resolving Employment Tax Disputes
  • May, 2020 – CalCPA – What Professionals Need to Know About PPP Loans and Employee Retention Credits
  • March, 2020 – Strafford – Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Advisers
  • January, 2020 – USC Gould Tax Institute –  Protecting Your Clients Privileges in Tax Matters – “Here and Abroad”
  • November, 2019 – CalCPA – Evasion of Payment Lecture
  • October, 2019 – UCLA Tax Controversy Institute – The Growing Role of LB&I in Tax Enforcement
  • June, 2019 – 11th Annual NYU Tax Controversy Institute – IRS Small Business/Self-Employed Division Update of the Tax Compliance and Enforcement
  • June, 2019 – Oregon Tax Institute – Current IRS Enforcement Objectives, Ways in which IRS Detects and Pursues these Objectives and Taxpayer Defense Alternatives
  • December, 2018 – ABA 35th National Institute on Criminal Tax Fraud and 8th Annual National Institute on Tax Controversy – Ethical and Other Issues When Representing Non-Compliant Taxpayers: Domestic and Foreign Voluntary Disclosures in a Post-Program World
  • October, 2018 – UCLA 34th Annual Tax Controversy Institute – Goodbye Offshore Voluntary Disclosure Program Hello Litigation of International Reporting Penalties
  • July, 2018 – Beware of Kovel Accountants
  • May, 2018 – Representing Taxpayers in Collection Matters Before the IRS
  • May, 2018 – ABA Tax Section – Civil and Criminal Employment Tax Enforcement Efforts Employers Beware
  • January, 2018 – California Non-Residency Determinations A Temporary and Transitory Visit with California Residency
  • November, 2017 – 76th NYU Institute on Federal Taxation – From the Experts: IRS Representation Tool, Techniques and Defensive Strategies – Civil & Criminal Tax Update
  • October, 2017 – UCLA 33rd Tax Controversy Institute – Capturing the Small Captive Insurance Company
  • August, 2017 – California Society of CPAs – From the Trenches 150+ Years of Tax Disputes
  • August, 2017 – California Society of CPAs , RJS Law Tax Controversy Institute
  • – Captive Insurance Tax Controversies
  • December, 2016 – CalCPA Education Foundation – US–Mexico Conference & Professional Issue
  • May, 2016 – ABA Tax Section – Civil and Criminal Employment Tax Enforcement Efforts – Employers Beware
  • January, 2016 – USC Gould 2016 Tax Institute -Tips from The Trenches and IRS Examination Collection  Representation
  • November, 2015 – BHBA the 41st Annual Family Law Symposium – Tax Affecting S Corporation for Business Valuations – Cases
  • November, 2015 – 2015 Annual Meeting of the CA Tax Bar – Perfect Your Advocacy Skills & Develop Advanced Trial Techniques
  • November, 2015 – Jewish Community Foundation Lecture – Disclosures and Their Impact on Statutes of Limitation and Penalties on Estate and Gift Tax Returns and Related Issues
  • October, 2015 – 2014 Annual Meeting of the CA Tax Bar – My Tax Court Case Is Calendared.  Now What Do I Do,?
  • November, 2014 – 2014 Annual Meeting of CA Tax Bar – My Tax Court Case Is Calendared.  Now what do I do?,
  • June, 2014 – LA County Bar – 2014 CA Tax Practitioner’s Conference
  • June, 2014 – STEP LA 2014 – 2014 Cross-Border Compliance & Enforcement
  • April, 2014 – AFDA’s White Collar Roundtable Webinar
  • July, 2009 – CALCPA Lecture – LA Taxation Committee–IRS Enforcement in the Tax Gap
  • January, 2009 – Litigating Employee or Independent Contractor Status – A View from The Trenches
  • January, 2009 – Labor & Employment Relations Association Annual Meeting
  • October, 2008 – UCLA Tax Controversy Institute – Worker Classification and Techniques
  • October, 2008 – CAL State LA – Criminal Tax Enforcement
  • July, 2008 – CALCPA Lecture – Enforcement Activities & Initiatives at the IRS, FTB and EDD
  • August, 2007 – Santa Barbara Society CPA – Current Enforcement Priorities of the Internal Revenue Service and Franchise Tax Board
  • March, 2007 – Estate Planning in the Crucible: How to Defend an Estate Plan in Appeals and in the Tax Court, Society of Trust and Estate Practitioners USA
  • February, 2007 – Beverly Hills Bar Association – Litigation of an Income Tax Case Before the U.S. Tax Court
  • March, 2004 – CPA/Law Society of Ventura County – Federal Tax Update
  • November, 2003 – Santa Barbara County Bar Association – Federal Tax Controversy Update
  • October, 2003 – Cal State University, Los Angeles – Jobs and Growth Tax Relief and Reconciliation Act of 2003 and Other Recent Tax Developments
  • March, 2003 – CPA/Law Society of Ventura County – Federal Tax Litigation Update
  • June, 2003 – Whittier Law School 2002 Annual Income Tax Seminar – New Federal Tax Legislation/Income Tax Update
  • 2003 – Cal State University, Los Angeles – Individual Tax Update
  • November, 2002 – Central Coast CPA/Law Society – Federal Tax Litigation Update: Innocent Spouse, Employment Taxes, Criminal Enforcement Initiatives and Related Areas
  • November, 2002 – California CPA Education Foundation – IRS Enforcement
  • March, 2002 – Federal Tax Litigation Update: Innocent Spouse, Employment Taxes
    Criminal Enforcement Initiatives and Related Areas
    March, 2002 – Ventura County CPA/Law Society
  • February, 2002 – Center for International Legal Studies – Current Developments in Internal Revenue Service Criminal Investigation Enforcement Initiatives and Cases

Publications:

  • Co-Author: “Recently Proposed Amendment to the Federal Sentencing Guidelines Affect Criminal Tax Cases” with Steven Toscher, CCH Journal of Tax Practice and Procedure, December 2012-January 2013
  • Co-Author: “What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account?” with Edward Robbins, Jr. and Steven Toscher, CCH Journal of Tax Practice & Procedure, October-November 2012
  • Co-Author: “Tax Crimes”, Bureau of National Affairs (BNA) – Tax Management, Publication 636 (1993, revised 2012).
  • Co-Author: “IRS Audits of Attorneys’ Tax Returns” with Lacey Strachan, Los Angeles Lawyer, April 2012
  • Co-Author: “The IRS 2011 Offshore Voluntary Disclosure Initiative” with Charles P. Rettig, Los Angeles Lawyer, June 2011
  • Author: “New Tax Relief for Victims of Ponzi Schemes,” Los Angeles Lawyer, October 2009
  • Co-Author: “Counseling Corporations Involved in Government Investigations and the Principles of Federal Prosecution of Business Organizations” with Charles Rettig, Steven Toscher, and Edward M. Robbins, Jr., Corporate Business Taxation Monthly, February 2009
  • Co-Author: “Sentencing Discretion After Booker and the IRS/DOJ Expedited Plea Program” with Steven Toscher, CCH Journal of Tax Practice and Procedure, December 2005-January 2006
  • Co-Author: “Discretion is Back in the Sentencing of Tax Defendants–At Least for Now” with Steven Toscher, BNA Tax Management, February 2005
  • Author: “2005 California Tax Amnesty,” Tax Tips, Los Angeles Lawyer, December 2004
  • Co-Author: “How the IRS Distinguishes Civil and Criminal Tax Fraud” – L.A. Lawyer – October, 2003
  • Co-Author: “The Crime Fraud Exception to the Attorney-Client Privilege”, CCH Journal of Tax Practice and Procedure (June 2000)
  • Author: U.S. Tax Court Settlement Judge Procedure, California State Bar Taxation Section, Washington D.C. Trip, (May 1996)

Honors and Affiliations:

  • Chambers USA High Net Worth Guide Tax: Private Client USA Rankings
  • First recipient of the Sam Lipsman Service Award
  • Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization
  • Elected Fellow, American College of Tax Counsel
  • United States Tax Court Judicial Conference, 1997, 2003, 2007
  • Adjunct Professor, Golden Gate University Graduate School of Taxation (1999 to present)

Member:

  • Chair, Los Angeles Lawyer Editorial Board
  • President, UCLA Law School Alumni Board of Directors
  • Member, Los Angeles Lawyer Editorial Board
  • Fellow, American College of Tax Counsel
  • Past Chair, State Bar of California Tax Procedure & Litigation Subcommittee
  • Past-Chair of the Tax Procedure & Litigation Subcommittee of the Los Angeles County Bar Association
  • Member, Association of Tax Counsel
  • Second Vice-Chair Taxation Section, Executive Committee, California State Bar
  • Planning Committee of the UCLA Extension Annual Tax Controversy Institute
  • National Association of Criminal Defense Lawyers
  • Producer, U.S. Tax Court Pro Se Video

Bar Admittance:

  • S. Court of Appeals for the Ninth Circuit
  • S. Tax Court
  • S. District Court for Central, Eastern and Southern Districts of California
  • State Bar of California

Education:

  • University of California, Los Angeles (J.D.)
  • San Diego State University (A.B. English Cum Laude)