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Dennis Perez is the first recipient of the Los Angeles Lawyer Sam Lipsman Service Award

This award was established in memory of our late publisher Sam Lipsman, to honor an Editorial Board member or author who has provided exemplary service on behalf of Los Angeles Lawyer.  This is an individual who has made a long standing commitment and material contribution to the magazine by, for example, serving as Chair and … Continue reading Dennis Perez is the first recipient of the Los Angeles Lawyer Sam Lipsman Service Award

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The Judge Isn’t Bound by the Guideline Range in Sentencing by Robert Horwitz

Plea agreements in criminal tax cases normally have a section containing the calculation of the agreed Sentencing Guideline Range. The plea agreement also typically recites that the Government will recommend a guideline range sentence as long as the defendant meets his obligations under the plea agreement, but that the court is not required to accept … Continue reading The Judge Isn’t Bound by the Guideline Range in Sentencing by Robert Horwitz

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IRS Increases Focus on Transactions Between Commonly Controlled Entities in the Mid-Market Segment by Lacey Strachan

Large multinational corporations have historically been the focus of IRS transfer pricing examinations, such as the dispute between Amazon and the IRS over the amounts Amazon charged its European subsidiary for certain intangible assets that were transferred.[i]  However, IRS efforts to address potential income shifting between related entities have expanded to include smaller companies in … Continue reading IRS Increases Focus on Transactions Between Commonly Controlled Entities in the Mid-Market Segment by Lacey Strachan

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IRS Collection Appeals “Dead Ends”– Collection Due Process Procedural Traps for the Unwary by Cory Stigile

In Keller Tank Services II Inc. v. Commissioner, 848 F.3d 1251 (10th Cir. 2017), the Tenth Circuit affirmed the Tax Court’s holding that a taxpayer could not challenge a Section 6707A penalty during a collection due process hearing or in a subsequent Tax Court proceeding because it already challenged the penalty with the IRS Appeals … Continue reading IRS Collection Appeals “Dead Ends”– Collection Due Process Procedural Traps for the Unwary by Cory Stigile

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IRS Increases Focus on Transactions Between Commonly Controlled Entities in the Mid-Market Segment by Lacey Strahan

Large multinational corporations have historically been the focus of IRS transfer pricing examinations, such as the dispute between Amazon and the IRS over the amounts Amazon charged its European subsidiary for certain intangible assets that were transferred.[i]  However, IRS efforts to address potential income shifting between related entities have expanded to include smaller companies in … Continue reading IRS Increases Focus on Transactions Between Commonly Controlled Entities in the Mid-Market Segment by Lacey Strahan

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Steven Toscher Quoted in Tax Notes Article on Receiving Non-Prosecution Letters From DOJ

DESPITE LESS CERTAINTY, SWISS BANK NON-TARGET LETTERS VALUABLE Published by Tax Analysts, Tax Notes Today Although some practitioners question the potential value of non-target letters available to institutions in categories 3 and 4 of the Justice Department’s Swiss bank program, others point out the value of non-target letters in the general criminal context and the request for the … Continue reading Steven Toscher Quoted in Tax Notes Article on Receiving Non-Prosecution Letters From DOJ

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Steven Toscher Quoted in Tax Notes on Proposed Changes to FBAR rules

FBAR CHANGES TRY TO BALANCE COMPLIANCE BURDEN, ENFORCEMENT. Published by Tax Analysts(R) A new proposal from Treasury’s Financial Crimes Enforcement Network regarding the filing of Form 114, “Report of Foreign Bank and Financial Accounts,” would substantially change what is required of some financial professionals who file the foreign bank account reports as part of their … Continue reading Steven Toscher Quoted in Tax Notes on Proposed Changes to FBAR rules

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Judge L. Paige Marvel has been elected as Chief Judge of the United States Tax Court

UNITED STATES TAX COURT Washington, D.C. 20217 February 29, 2016 PRESS RELEASE The United States Tax Court announced today that Judge L. Paige Marvel has been elected as Chief Judge of the United States Tax Court to serve a 2-year term beginning June 1, 2016.  The election of the Chief Judge by the Judges of … Continue reading Judge L. Paige Marvel has been elected as Chief Judge of the United States Tax Court

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If You Want to Recover Costs in Fighting the IRS, Ask on Time By Robert S. Horwitz

Internal Revenue Code sec. 7430, a taxpayer can recover administrative and litigation costs, including attorney fees, if the taxpayer is the prevailing party and the IRS’s position was not substantially justified. There is one hitch: you have to ask for costs and fees before it’s too late.  This is what the taxpayers learned in Foote … Continue reading If You Want to Recover Costs in Fighting the IRS, Ask on Time By Robert S. Horwitz

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IRS Employment Tax Notices Must be Sent to the “Last Known Address” of the Taxpayer, by ROBERT S. HORWITZ

The IRS has recently enhanced their focus on employment tax enforcement throughout the country. An employment tax return filed by April 15 of the year following that in which the applicable quarter falls is “deemed filed” on April 15 of the following year. Where no return is filed, the three-year assessment period does not begin to run … Continue reading IRS Employment Tax Notices Must be Sent to the “Last Known Address” of the Taxpayer, by ROBERT S. HORWITZ

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“GOTCHA” — UNANTICIPATED AUDIT ISSUES AFTER QUIET DISCLOSURES By Frank Agostino and Lawrence A. Sannicandro

ANOTHER GREAT ARTICLE FROM AGOSTINO & ASSOCIATES!!  – To download a great article prepared by our very close friends at the Law Firm of Agostino & Associates in Hackensack, NJ (www.agostinolaw.com), see the Agostino & Associates February Newsletter – http://files.ctctcdn.com/f7d16a55201/5f66c5a0-157c-4050-bbdd-81087e8b2275.pdf “GOTCHA” — UNANTICIPATED AUDIT ISSUES AFTER QUIET DISCLOSURES By Frank Agostino, Esq. and Lawrence A. … Continue reading “GOTCHA” — UNANTICIPATED AUDIT ISSUES AFTER QUIET DISCLOSURES By Frank Agostino and Lawrence A. Sannicandro

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IRS Transaction Codes Pocket Guide – Helpful if You Need it ! by Robert Horwitz

The IRS transaction codes are typically listed on an taxpayers transcript of account. The transaction guide identifies many of the most often used codes. “This document is an abbreviated version of the Transaction Codes listed in Document 6209 for quick reference. The transaction codes consist of three digits. They are used to identify a transaction … Continue reading IRS Transaction Codes Pocket Guide – Helpful if You Need it ! by Robert Horwitz

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