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Tax Court Update: Basis for Cohan Rule by Jonathan Kalinski

As we approach the tax return filing deadline of April 17 this year, taxpayers are scrambling for documents to substantiate their expenses and basis in assets. Tax practitioners are always asked low long should one keep records.  Three years?  Seven years?  Forever?  If you find yourself without records, all may not be lost thanks to … Continue reading Tax Court Update: Basis for Cohan Rule by Jonathan Kalinski

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ZAPPER UPDATE: WASHINGTON ATTORNEY GENERAL ZAPS TACO RESTAURANTS by Evan J. Davis

There’s been a recent uptick in state and federal prosecutions of restaurants who use sales-suppression software (also known as “zappers”) that delete transactions on computerized point-of-sale systems, as governments have finally woken up to the fact that they are losing tens of billions of dollars per year in underreported sales and income taxes. These zapper … Continue reading ZAPPER UPDATE: WASHINGTON ATTORNEY GENERAL ZAPS TACO RESTAURANTS by Evan J. Davis

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ENCORE PRESENTATION – WEBINAR featuring Steven Toscher and Michel Stein – New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment

New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment Strafford April 24, 2018 – 10:00 a.m. – 11:30 p.m. (Pacific) Due to an overwhelming popularity, Steven Toscher and Michel Stein will be hosting an encore presentation of the Strafford Webinar “New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment” The panel will provide … Continue reading ENCORE PRESENTATION – WEBINAR featuring Steven Toscher and Michel Stein – New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment

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Supreme Court Reins in Criminal Tax Prosecutions by Robert S. Horwitz

Did you ever fail to keep complete and accurate records? Pay someone in cash? Not give an accountant all your records? Deposit a business check in a personal account? Thanks to the Supreme Court’s March 21 decision in Marinello v United States, 584 U.S. ___, you won’t have to worry that these acts can lead to … Continue reading Supreme Court Reins in Criminal Tax Prosecutions by Robert S. Horwitz

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Two IRS Pronouncements on Penalties by Robert S. Horwitz

When it comes to taxes, Congress is penalty happy. There are over 150 separate penalties that can be imposed for various infractions of the Internal Revenue Code.  Two recent IRS pronouncements address penalties. First Time Abatement Relief Among the myriad of penalties, the Internal Revenue Code provides for the penalties for: Failure to file a … Continue reading Two IRS Pronouncements on Penalties by Robert S. Horwitz

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Ninth Circuit Holds Time Limit for Filing Challenge to Collection Due Process Determination Is Jurisdictional; Does that Mean Time Limit for Seeking Redetermination of a Deficiency Is Not? by Robert S. Horwitz

In recent years, the United States Supreme Court has wrestled with the issue of whether time limits for bringing administrative and judicial actions against the Federal Government jurisdictional. In Sebelius v Auburn Regional Medical Center, 568 U.S. __, Justice Ginsburg, writing for the majority, stated: Characterizing a rule as jurisdictional renders it unique in our … Continue reading Ninth Circuit Holds Time Limit for Filing Challenge to Collection Due Process Determination Is Jurisdictional; Does that Mean Time Limit for Seeking Redetermination of a Deficiency Is Not? by Robert S. Horwitz

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SANDRA R. BROWN First Assistant United States Attorney and the Former Acting United States Attorney for the Central District of California’s United States Attorney’s Office has Joined Our Firm as a Principal

HOCHMAN SALKIN RETTIG TOSCHER & PEREZ. PC announced that SANDRA BROWN, former Acting United States Attorney of the Central District of California, will join the Firm as a Principal on March 5, 2018, where she will handle all phases of civil and criminal tax controversies, including trials and appeals. CHARLES RETTIG, Managing Principal of the … Continue reading SANDRA R. BROWN First Assistant United States Attorney and the Former Acting United States Attorney for the Central District of California’s United States Attorney’s Office has Joined Our Firm as a Principal

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Message from Chairs Charles Rettig and Steven Toscher

For 33 YEARS, the Annual Tax Controversy Institute has been among the preeminent tax conferences in the United States exclusively dedicated to tax controversy and tax litigation! This year, Steve Toscher and I were honored and privileged to serve as Co-Chairs of The Annual Tax Controversy Institute! Institute Chair Emeritus. The Institute was founded by … Continue reading Message from Chairs Charles Rettig and Steven Toscher

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See What Procedurally Taxing is Saying About the New Nominee for IRS Commissioner CHARLES RETTIG

Procedurally Taxing February 20, 2018 by: Keith Fogg The press reports that President Trump would nominate Chuck Rettig as the new IRS Commissioner were followed with a formal announcement. Assuming he is confirmed, Mr. Rettig will serve as the first tax lawyer in this position in the new millennium. I applaud the return to having someone run the … Continue reading See What Procedurally Taxing is Saying About the New Nominee for IRS Commissioner CHARLES RETTIG

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We Are Pleased to Announce That LACEY STRACHAN Has Been Named Principal Of Our Firm

Lacey Strachan concentrates her practice in complex civil tax litigation and criminal tax prosecutions (jury and non-jury) before the federal district courts, the U.S. Tax Court, the U.S. Court of Federal Claims, and the Ninth Circuit Court of Appeals. Ms. Strachan represents individuals, corporations, pass-through entities, trusts, and estates in all stages of state and … Continue reading We Are Pleased to Announce That LACEY STRACHAN Has Been Named Principal Of Our Firm

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Cryptocurrency Tax Webinar Hosted By Colleagues Of IRS Nominee Charles Rettig by Matthew De Silva of ETHNews.COM

On February 15, 2018, tax attorneys Steven Toscher and Michel R. Stein, principals at Hochman Salkin Rettig Toscher & Perez P.C., delivered a presentation entitled “New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment.” Earlier this month, President Trump nominated Charles Rettig, one of Toscher and Stein’s colleagues, to serve as commissioner of … Continue reading Cryptocurrency Tax Webinar Hosted By Colleagues Of IRS Nominee Charles Rettig by Matthew De Silva of ETHNews.COM

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STEP/LA Luncheon Presentation featuring STEVEN TOSCHER – Festival of Forms Featuring Form 5471 Substantial Compliance Rules

  Friday, February 16, 2018 12:00 p.m. – 1:30 p.m. Northern Trust 2049 Century Park East, Suite 3600 Los Angeles, CA 90067 Steven Toscher of Hochman Salkin Rettig Toscher & Perez and John Apuzzo of PricewaterhouseCoopers LLP, will discuss an interesting topic about the encore presentation the Strafford webinar, “Form 5471 Substantial Compliance Rules: New … Continue reading STEP/LA Luncheon Presentation featuring STEVEN TOSCHER – Festival of Forms Featuring Form 5471 Substantial Compliance Rules

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