TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, March 04, 2024

We are also pleased to announce that Sandra R. Brown will be moderating a panel at the upcoming ABA 39th National Institute on White Collar Crime on the topic of “The Powers and Perils of Parallel Criminal and Civil Investigations” on Wednesday, March 6, 2024, 10:30 a.m. (PST), with panelists Ronald Cheng (Pillsbury Winthorp), Caroline Ciraolo (Kostelanetz), Mary Hammond (IRS Global Operations […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, March 01, 2024

We are pleased to announce that Michael Greenwade along with Andrea N. Erdahl (SBSE Examination) will be speaking at the upcoming Beverly Hills Bar Association webinar “The Fundamentals of Information Reporting” Tuesday, March 5, 2024, 12:30 p.m. – 1:30 p.m. (PST). This program will go over the fundamentals of compliance related to international information return filings in order to provide […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, February 29, 2024

We are pleased to announce that Sandra R. Brown will be speaking at the upcoming Federal Bar Association 2024 Tax Law Conference on the topic of “May You Live in Interesting Times – The Latest in Criminal Investigations and Sentencings” on Tuesday, March 5, 2024, 11:00 a.m. – 12:00 p.m. (PST), along with co-panelists Caroline Ciraolo (Kostelanetz), Eric Hylton (alliantgroup), and Jeffrey […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 28, 2024

The Taxpayer Advocate Service (TAS) is an independent organization within the Internal Revenue Service (IRS), which prides itself on being the “Voice of the Taxpayer” with the IRS and before Congress. By statute, the National Taxpayer Advocate (NTA), a position held by Erin Collins, who heads TAS, is required to submit an Annual Report to Congress […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, February 22, 2024

We are pleased to announce that Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming Strafford webinar “IRS’ Current Audit Campaign: Preparing for Large Partnership, Complex PTE, and HNW Taxpayer” Tuesday, February 27, 2024, 10:00 a.m. – 11:50 a.m. (PST). In Notice 2023-166, the IRS announced its shift in focus from working-class taxpayers to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 16, 2024

We are pleased to announce that Evan Davis will be speaking at the upcoming USD School of Law – Chamberlain International Tax Institute Conference on the on the topic of “Attorney-Client Privilege and Confidentiality Limitations in International Tax Matters” on Monday, February 19, 2024, 3:00 p.m. – 4:00 p.m. (CST), along with co-panelists  Ana Elena Domínguez, Galicia Abogados (Mexico City), Jeremy Temkin, Morvillo, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, February 15, 2024

We are pleased to announce that Dennis Perez, Michel R. Stein, and Jonathan Kalinski will be speaking at the upcoming CalCPA webinar “Resolving Federal and State Employment Tax Matters – Worker Classification” Tuesday, February 20, 2024, 9:00 a.m. – 10:00 a.m. (PST). The IRS is increasing both civil and criminal enforcement against taxpayers who fail to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 12, 2024

We are pleased to announce that Michel R. Stein will be speaking at the upcoming 11th Annual Florida Tax Institute  3-Day Conference on the on the topic of “Audits and Tax Controversy Update” on Wednesday, February 14, 2024, 2:15 p.m. – 3:15 p.m. (EST), along with co-panelists Fred Murray (IRS Special Counsel), Eric Cerelli (IRS Field […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, January 31, 2024

In two recently issued decisions, the U.S. Tax Court reaffirmed the validity of the so-called “Cohan Rule” that allows the Court to estimate the amount of a taxpayer’s deductible expenses so long as the taxpayer clearly shows that he or she incurred the expenses and the Court has a reasonable basis for making such an […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, January 26, 2024

We are pleased to announce that Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming Strafford webinar “Navigating IRS Corporate and High-Income Taxpayer Audits: Key Areas of Focus for Examinations, Pitfalls to Avoid” Thursday, February 1, 2024, 10:00 a.m. – 11:30 a.m. (PST). The IRS has rolled out its plan for increased […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, December 27, 2023

Congratulations to Sandra R. Brown and Hunter Keaster for being featured on the December 2023 cover of the Los Angeles Lawyer Magazine. Sandra and Hunter are highlighted for their article “Closing the Gap” which analyzes the IRS’s Strategic Operating Plan for improving taxpayer services and reducing the tax gap through stricter enforcement with the current $60 […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, December 26, 2023

On December 21, 2023, as part of its ongoing effort to address and combat dubious claims for the Employee Retention Credit (ERC), the IRS unveiled a new Voluntary Disclosure Program aimed at helping businesses rectify errors in previously submitted ERC filings. The new initiative comes in response to growing concerns about the legitimacy of certain […] Read More…