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STRAFFORD SEMINAR Presented by Steven Toscher and Michel R. Stein: Tax Law 2018: New Challenges and Opportunities: New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements & Exchange Treatment

Thursday, May 10, 2018, New York City 10:45 a.m. – 12:15 p.m. Eastern Time Steven Toscher and Michel Stein will be speaking in New York City at an upcoming Strafford seminar/webinar, New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements and Exchange Treatment scheduled for Thursday, May 10th, 10:45 a.m. – 12:15 p.m. EST. Tax reform and … Continue reading STRAFFORD SEMINAR Presented by Steven Toscher and Michel R. Stein: Tax Law 2018: New Challenges and Opportunities: New IRS Scrutiny on Cryptocurrency Reporting: Filing Requirements & Exchange Treatment

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PRESENTATION: Beverly Hills Bar Association: Cryptocurrency and IRS Tax Enforcement presented by Steven Toscher and Michel Stein

Steven Toscher and Michel Stein will be speaking at an upcoming Beverly Hills Bar Association presentation, “Cryptocurrency and IRS Tax Enforcement” scheduled for Thursday, May 17th at noon.  Presentation from 12:30 p.m. – 1:30 p.m. The presentation will provide tax professionals with a critical first look at new IRS initiatives on taxpayer compliance and reporting … Continue reading PRESENTATION: Beverly Hills Bar Association: Cryptocurrency and IRS Tax Enforcement presented by Steven Toscher and Michel Stein

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Tax Problem for Departing Aliens by Steven Toscher

The regulations[1] require that no alien, whether resident or non-resident, can depart from the United States unless he or she first procures a certificate that he or she has complied with the obligations imposed upon him or her by the income tax laws.[2]Failure to do so may result in a termination assessment. Certain types of individuals, … Continue reading Tax Problem for Departing Aliens by Steven Toscher

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Tax Court Limits IRS’s Time to Assess Unreported Income from Undisclosed Foreign Accounts by Sandra R. Brown

Generally, when a taxpayer files a tax return, the federal tax laws afford the Internal Revenue Service (“IRS”) with a limit of only three-years within which it must act to examine and assess additional taxes and penalties on any unreported income. While the Internal Revenue Code provides various exceptions to this three-year limit[i], on January 2, 2018, the Tax … Continue reading Tax Court Limits IRS’s Time to Assess Unreported Income from Undisclosed Foreign Accounts by Sandra R. Brown

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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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