The Tax Division handles all civil tax litigation involving the federal government in the Central District of California, other than in the Tax Court. The Tax Division also handles prosecution of certain criminal tax violations.
AUSAs in the Tax Division represent the government in federal and state civil actions and proceedings in which the IRS is involved or where the defendant is an IRS officer or employee sued for official acts. Tax Division AUSAs appear before the United States District Court, the United States Bankruptcy Court, the United States Bankruptcy Appellate Panel, and the state courts.
Tax Division AUSAs handle a variety of civil tax cases and matters, including suits for refund of income, employment, excise, estate and gift taxes; suits to collect delinquent tax liabilities and to foreclose federal tax liens (including fraudulent conveyance actions); adversary proceedings and contested matters in bankruptcy (including objections to tax claims, objections to confirmation of Chapter 11 and 13 reorganization plans and complaints to determine dischargeability of debt and for turnover of property); actions to enforce IRS summonses; suits for summary review of jeopardy and termination assessments; suits to recover wrongfully levied property; suits for damages for failure to release levy and wrongful collection activity; suits against IRS employees for constitutional torts; actions affecting property in which the United States claims a tax lien (including actions in interpleader, eminent domain and for partition); and probate proceedings. Tax Division AUSAs also handle a variety of criminal tax prosecutions, including tax evasion and the filing of false tax returns.
Sandra Brown, Chief
Sandra Brown obtained her B.S. in Business Administration from Central Michigan University (1986), her JD from Western Michigan University Cooley Law School (1989), and her LL.M. in Taxation from the University of Denver (1990). AUSA Brown has been an Assistant U.S. Attorney in the Tax Division of this office since 1991. AUSA Brown has been the Chief of the Tax Division, since October 2004. Prior to that position, AUSA Brown was appointed as the very first Deputy Chief for Criminal Tax Matters in the Tax Division, a position which she held until her appointment as Division Chief. As an AUSA, AUSA Brown has litigated a number of nationally important tax cases, including two Supreme Court decisions (Brockamp v. US, 519 U.S. 347 (1997) and Williams v. US, 514 U.S. 527 (1995)). AUSA Brown was nominated for a Director’s Award based upon her work in several significant cases including a Bivens action, which resulted in the favorable, published decision in Andersen v. US, 298 F.3d 804 (9th Cir. 2002), as well as nominated for both the Attorney General’s “AG” Award for Fraud Prevention and the Director’s Award for her successful prosecution in US v. Gene Haas, one of the largest tax restitution orders collected in a legal source criminal tax case ever prosecuted in this nation, as well an AG’s award in connection with her development of a nationwide “best practices” program to further the Attorney General’s policy on parallel proceedings. Most recently, AUSA Brown has been nominated for the AG’s Award for Distinguished Service in connection with her work on the unprecedented Deferred Prosecution Agreement spanning four countries, Bank Leumi le-Israel, B.M., Bank Leumi Trust Company, Ltd. Bank Leumi (Luxembourg) S.A., Leumi Private Bank S.A., and Bank Leumi USA, resolving a four-year criminal probe into Bank Leumi's worldwide U.S. cross-border business, requiring Bank Leumi to pay $270 million in restitution and fines to the United States and to provide details about employees and more than 1,500 U.S. customers. AUSA Brown is the recipient of the Internal Revenue Service Criminal Investigation Chief’s Award, which is the highest recognition given by the IRS CID to a non-IRS employee, as well as the IRS’s Mitchell Rogovin National Outstanding Support of the Office of Chief Counsel Award, which recognizes DOJ attorneys for superior abilities to provide support to the Office of Chief Counsel and significant contributions to agency-wide and interagency work, making her possible the only AUSA in the nation to have been recognized by the IRS with its highest honors for both her criminal and civil tax contributions. AUSA Brown is an active member of the DOJ Tax Division Civil Chiefs’ working group, teaches at the National Advocacy Institute in South Carolina, serves on the DOJ Evaluation and Review Staff “EARS” as an evaluator for other US Attorney offices, and is a regular speaker at outside events sponsored by tax related CLE/CPE entities.
The United States Attorney's Office