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Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, May 15, 2015

Historically, Internal Revenue Service examiners were assigned to audit taxpayers in many different industries. On one day, an examiner audited a grocery store and on the following day the examiner may have audited a computer retailer or a medical doctor. As a result, experience gained in one audit did not significantly enhance the examiner’s experience […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 04, 2015

IRS Audit or investigative techniques for a cash intensive business might include an examiner determining that a large understatement of income could exist based on return information and other sources of information. A cash intensive business is one that receives a significant amount of receipts in cash. This can be a business such as a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, May 01, 2015

The Clinton Foundation recently announced that it will be amending various previously filed annual information returns to, at least in part, reflect donations on a specific, rather than consolidated, basis.[1] IRS Form 990, “Return of Organization Exempt From Income Tax,” is an annual information return filed by organizations exempt from income tax under Internal Revenue […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, April 11, 2015

In Knudsen v. Commissioner, T.C. Memo 2015-69, the Tax Curt recently denied the IRS’s motion for summary judgment where the taxpayer challenged a proposed collection levy because the IRS failed to establish that it actually mailed the required notices of deficiency to the taxpayer.  The Tax Court concluded a trial is necessary to determine whether […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 08, 2015

In a recent case of first impression, the U.S. Tax Court held that in “stand alone” innocent spouse cases under I.R.C. section 6015(e)(1) the Court has discretion to allow the petitioner to withdraw the petition without entering a decision because petition does not invoke the Court’s deficiency jurisdiction.[1]  The taxpayer filed a Form 8857, Request […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, March 22, 2015

Does filing a false return start the six year clock or does it start at the time of the taxpayer’s last act of tax evasion? A taxpayer’s last act of tax evasion may occur many years after the tax return was (or should have been) filed. Some courts have concluded that the six year statute […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, March 07, 2015

In a Tax Court Memorandum Opinion released February 26, 2015, the Tax Court held that a taxpayer had fully reported his tip income for tax years 2009 – 2011, rejecting the Service’s determination that the taxpayer had underreported his tip income based on its reconstruction of the taxpayer’s tip income.[i]  During the tax years at […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 27, 2015

Deductions are a matter of legislative grace, and taxpayers bear the burden of proving entitlement to any claimed deduction.[i] A taxpayer must identify each deduction available, show that he or she has met all requirements therefor, and keep books or records that substantiate the expenses underlying the deduction.[ii] The mere fact that a taxpayer claims […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 25, 2015

Cono Namorato is an extraordinary individual with an outstanding character and the highest integrity. He is amazingly well qualified to lead the Tax Division with his deep knowledge and understanding of the Internal Revenue Code, the Treasury Regulations and relevant case authorities involved in a wide range of both civil and criminal tax related issues. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 20, 2015

ABA Webinar “ANSWERING YOUR CIVIL AND CRIMINAL OFFSHORE DISCLOSURE QUESTIONS” – Tuesday, February 24, 2015 at 12:00 to 1:30PM ET.   Following on the success of the recent ABA National Institutes of Criminal Tax Fraud and Tax Controversy, this program will provide a brief overview of offshore tax enforcement, followed by an opportunity to present questions directly […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 09, 2015

THE INTERNATIONAL CONSORTIUM OF INVESTIGATIVE JOURNALISTS(ICIJ) have released information regarding “a trove of almost 60,000 leaked files that provide details on over 100,000 HSBC clients and their bank accounts.” See  https://www.icij.org/project/swiss-leaks/explore-swiss-leaks-data ICIJ DISCLAIMER – A Disclaimer on the ICIJ site states “There are legitimate uses for Swiss bank accounts and trusts. We do not intend […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, February 07, 2015

Section 1031 like-kind exchanges have been one of the California Franchise Tax Board’s (FTB) top audit issues in recent years. [i]  California’s Form 3840, which is new for the 2014 tax year, is one of the latest developments in the FTB’s focus on scrutinizing like-kind exchanges. On June 27, 2013, Assembly Bill 92 was enacted, […] Read More…