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DENNIS PEREZ Quoted in Tax Notes Article: IRS Using FATCA Criminal Indictments to Pursue Tax Evaders

Ten years after starting to aggressively pursue Swiss banks that helped U.S. persons evade taxes, the IRS is continuing to mine the trove of information gathered to criminally pursue the account holders and their facilitators. A pair of practitioners with extensive experience at the IRS said U.S. taxpayers with undisclosed foreign accounts who do not […] Read More…

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Maintaining Privileges When Kovel Accountants Prepare Tax Returns by Evan Davis

Maintaining Privileges When Kovel Accountants Prepare Tax Returns by Evan Davis

Is this merely a theoretical problem? No. The IRS and Justice Department are pursuing Kovel communications aggressively. Lawyers who aren’t careful about how and when they use Kovel accountants are at serious risk of losing privilege protections and giving the government a window into the attorney-client relationship. Although it’s impossible to entirely avoid risk in this area, here are suggestions […] Read More…

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AVRAM SALKIN Receives UCLA Lifetime Achievement Honor featured in Beverly Hills Courier

AVRAM SALKIN Receives UCLA Lifetime Achievement Honor featured in Beverly Hills Courier

Avram Salkin, a noted tax lawyer who has practiced in Beverly Hills for the past 58 years on Tuesday at The Beverly Hills Hotel received the prestigious Bruce Hochman Award from the UCLA Tax Controversy as part of the 34th annual Tax Institute in recognition of this lifetime achievement in the practice of tax law. […] Read More…

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Pro Se Taxpayers Score Win in CDP Case and Receive a Formal Tax Court Opinion by Robert S. Horwitz

Pro se petitioners James and Tina Loveland hit a home run in a CDP case that resulted in a formal Tax Court opinion, Loveland v. Commissioner, 151 T.C. No. 7 (September 25, 2018), here.  The Tax Court has three levels of opinions: 1) a formal Tax Court opinion, which is published in the Tax Court Reporter and […] Read More…

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CCTP Updates – Important Developments: Criminal By Evan Davis and Claire Taylor

DEDUCTIBILITY AND INFORMATION REPORTING OF RESTITUTION PAYMENTS: TRANSITIONAL GUIDANCE ISSUED The Tax Cuts & Jobs Act made significant changes to Section 162(f) with respect to the deductibility of certain fines, penalties, and other amounts, including restitution payments. Previously, Section 162(f) barred a deduction for fines or penalties paid to a government for the violation of […] Read More…

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UCLA 34th Annual Tax Controversy Institute

UCLA 34th Annual Tax Controversy Institute

Plan on joining us on October 23rd to help celebrate the 34th anniversary for one of the preeminent conferences exclusively dedicated to tax controversy and tax litigation. The Annual Tax Controversy Institute provides an open forum for distinguished presenters and panelists to discuss, and often debate, sensitive tax practice issues with an engaged audience. MESSAGE […] Read More…

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How Long Should You Keep Tax-Related Records? by Cory Stigile

The length of time you should keep a document depends on the action, expense, or event which the document records. Generally, you must keep your records that support an item of income, deduction or credit shown on your tax return until the period of limitations for that tax return runs out. For most taxpayers, the […] Read More…

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Cryptocurrency: Tax Ramifications and Enforcement Issues Podcast

Steven Toscher, Esq. and Michel Stein, Esq speaks with Eric Green, Esq.of the Tax Rep Network about everything you need to know about Cryptocurrency: What it is, how the IRS views cryptocurrency, how to report these transactions, can you do a like-kind exchange of cryptocurrency, why it’s such a hot button issue with the IRS […] Read More…

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EVAN DAVIS will be speaking at an upcoming Knowledge Group live webinar The Nuts and Bolts of Tax Penalties: A Practical Guide

We are pleased to announce that Evan Davis will be speaking at an upcoming Knowledge Group live webinar The Nuts and Bolts of Tax Penalties: A Practical Guide scheduled for Friday, September 21, 2018 from 12:30 p.m. to 2:00 p.m. Eastern Time. As the number of tax evasion or tax fraud cases continues to rise, […] Read More…

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Please Join STEVEN TOSCHER, SANDRA BROWN and EVAN DAVIS for Part One of Their Three Part Webcast Series Covering the Defense of Criminal Tax Cases Presented for the Association of Federal Defense Attorneys

The program is the first in a series of programs covering important topics in Federal Criminal Tax Enforcement and Litigation – including a post-mortem on the Manafort case. How Criminal Tax Cases Originate. Avoiding a Criminal referral from the Civil Examination or Collection Division of the IRS. The Administrative Conference Process—Unique to Tax Cases. Pre-Indictment […] Read More…

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SANDRA BROWN Quoted in Article on Rotating Fraud Technical Advisors

2018 TNT 159-3 ROTATING FRAUD TECHNICAL ADVISERS SEEN AS PROMISING IDEA (Doc 2018-32998) Tax Notes Today AUGUST 16, 2018, THURSDAY Copyright © 2018 Tax Analysts   Cite: 2018 TNT 159-3 Department: News, Commentary, and Analysis; News Stories Length: 1213 words Byline: Tax Analysts; Richman, Nathan J. Geographic: United States Published by Tax Analysts(R) The conversion […] Read More…

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ENCORE PRESENTATION – STRAFFORD WEBINAR Presented by Steven Toscher and Michel Stein : Tax Reporting of Bitcoin and Other Cryptocurrency: Calculating Basis, Income and Gain on August 29, 2018

This webinar will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and reporting income and gain on cryptocurrency (e.g. Bitcoin, Coinbase) transactions. The panel will discuss the IRS’ position on cryptocurrency as property rather than cash, analyze IRS monitoring to increase compliance, and define proper reporting and tax […] Read More…

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