Holtz, Slavett & Drabkin, APLC is proud to announce that David J. Warner has joined the firm as a tax attorney. David brings to Holtz, Slavett & Drabkin over 10 years of experience in tax controversy matters and was most recently a Senior Trial Attorney with the IRS Office of Chief Counsel.
David has extensive experience as a former Senior Trial Attorney with the IRS Office of Chief Counsel for 9 years. In this role, he represented the IRS in over 500 cases before the U.S. Tax Court, including the most complex cases with up to $25 million in taxes and penalties at issue. David was also designated a Special Assistant U.S. Attorney for the U.S. Department of Justice where he litigated tax matters in the U.S. Bankruptcy Court, including cases with up to $20 million in taxes at issue. As lead counsel of IRS Report of Foreign Bank and Financial Accounts (FBAR) Cadre for Southern California, it was his responsibility to review and approve hundreds of millions of dollars in FBAR penalties. David also advised the local Special Enforcement Program (SEP) and Large Business & International (LB&I) International Individual Compliance (IIC) revenue agents on complex domestic and international issues. As an expert inside the IRS on the taxation of partnerships and S corporations, David made presentations on these topics to hundreds of IRS attorneys across the country and was a founding member of the Southwest Area Partnership Cadre.
David was an Adjunct Professor of Law at Loyola Law School, University of California Irvine School of Law, and Chapman University Fowler School of Law, where he taught courses on tax practice and procedure, partnership tax, bankruptcy tax, and corporate tax.
David received an LL.M. in Taxation from New York University School of Law, where he was a graduate editor on the Tax Law Review and an M. Carr Ferguson Fellow in Tax Law. While at NYU, he won first prize in the Judge Tannenwald Writing Competition for the best article in the country on tax policy.
David earned his J.D., magna cum laude, from Loyola Law School in Los Angeles, where he ranked in the top five percent of his class and was inducted into the Order of the Coif. While at Loyola, David was the Chief Production Editor of the Loyola of Los Angeles Law Review and published an article on the Fourth Amendment and technology. He received his B.A. from the University of Minnesota where he majored in Political Science and History.
David is a member of the State Bar of California and is admitted to practice in the U.S. Tax Court and the U.S. District Court for the Central District of California. He also is a member of the California Bar Taxation Section and the Orange County Bar Association Tax Law Section.
David’s reported opinions include Palsgaard v. Commissioner, T.C. Memo. 2018-82; Pritchard v. Commissioner, T.C. Memo. 2017-136; Holden v. Commissioner, T.C. Memo. 2015-131; Alfaro v. Commissioner, T.C. Summ. Op. 2014-54; In re Gordian Medical, Inc., 499 B.R. 793 (Bankr. C.D. Cal. 2013).