Adjunct Professor of Law, University of San Diego School of Law, Graduate Tax Program, 1982-1985. Trial Attorney, U.S. Department of Justice, Tax Division, Criminal Section, 1975-1979. Assistant U.S. Attorney, Central District of California, Tax Division, 1979-1981. Author: "Criminal Tax Investigations" portion of Tax Practice in California Book; "The Innocent Spouse Provision" American Bar Association Journal, Jan, 1995, quoted: "Leaving A Trail Of Paper" California Law Business (Oct. 25, 1993). Lecturer: State Bar of California, "Attorneys as IRS Targets," (1995, 1996, 1997); California CPA Foundation, "Audit Roulette for High Income Individuals," (1997); California CPA Foundation "Tax Update Conference," (1998); California CPA Foundation "Statement and Fraud Conference" (2000 and 2004); California CPA Foundation Fraud in Audit, Accounting and Tax Conference, Tax Fraud (2006); University of California at Riverside, "What Every Attorney and Accountant Should Know About Tax Law and Procedure,"; California CPA Foundation, "Fraud Compliance,"; Orange County CPA Society, "Avoiding Civil and Criminal Penalties from Foreign Transactions," (1996); "Everything you Wanted to Know About Voluntary Disclosures," (2001); Ignoring the Form of a Transaction to Reduce Taxes (2004); University of California at Los Angeles Tax Disputes Institute (1987- "Discovery in the United States Tax Court, 1989- "TEFRA Tax Audits", 1995—"Criminal Tax Administrative Investigations and Grand Jury Proceedings," 2000; "Tax Litigation Techniques - A Motion to Compel"), California State University at Los Angeles, (1992—"An Overview of Tax Litigation Issues"), ESOP Association (1991- "Valuation Issues and ESOP Litigation") Orange County CPA Society, 1993- "Criminal and Civil Tax Issues in Use of Asset Protection Trusts and Foreign Bank Accounts"): International Association of Financial Planning, (1993- "Pitfalls Of Leaving Trusts and Family United Partnerships and Use of Foreign Trusts).