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Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 22, 2014

Requests to interview the taxpayer and/or return preparer during an otherwise normal IRS examination have become somewhat common. During the examination, the examining agent is auditing the return for accuracy and the taxpayer’s representative is typically trying to determine the nature and scope of the examination, gather responsive documents and information, etc. It is nearly impossible […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 15, 2014

Generally, subject to certain statutory exceptions, a debtor is permitted to discharge all debts that arose before the filing of his bankruptcy petition.[1] With respect to tax debts, the Bankruptcy Code provides that a debtor may not discharge any tax debts “with respect to which the debtor made a fraudulent return or willfully attempted in […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, September 12, 2014

Voluntary Disclosure. Practitioners often struggle with the issue of whether a taxpayer can avoid a criminal tax investigation by making a disclosure to the IRS.  A “voluntary disclosure” is generally the process of voluntarily reporting previously undisclosed income (or false deductions) through an amended return or the filing of a delinquent return. A taxpayer’s timely, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 08, 2014

For numerous reasons, many taxpayers fail to timely file required U.S. income tax returns and associated reports. A “non-filer” is described as a taxpayer (or someone who ought to be a taxpayer) who does not file their return before the deadline to file the next year’s return. A “late filer” is taxpayer who misses the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, September 02, 2014

AGOSTINO & ASSOCIATES –To download a few great articles prepared by our very close friends at the Law Firm of Agostino & Associates in Hackensack, NJ ( www.agostinolaw.com ), see the Agostino & Associates Newsletter https://doc-0g-a0-apps-viewer.googleusercontent.com/viewer/secure/pdf/3nb9bdfcv3e2h2k1cmql0ee9cvc5lole/a2e9d5ia6l9d8arb24i9qe55u5g1r2jr/1409675775000/drive/*/ACFrOgB3DcF0a_jTmvIpYCiuNKqO7L9fgn3s-OoYgXI80f841xzDJ5w3W4RQJIos9LXs1ctCT2z8v3FIziSDS2y-W6ct63hwuBzvEW_vnXAgbmb31pJpOwZuVMW1Ou8=?print=true DE NOVO REVIEW OF ASSESSABLE INTERNATIONAL PENALTIES By Frank Agostino, Brian D. Burton, and Lawrence A. Sannicandro    – Many taxpayers and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 26, 2014

All tax planning is not to be condemned. “It is no surprise that a knowledgeable tax attorney would use numerous legal entities to accomplish different objectives. This does not make them illegitimate. Unfortunately such ‘maneuvering’ is apparently encouraged by our present tax laws and codes.” [1] CIRCULAR 230 – Cir. 230 provides the regulations governing […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, August 20, 2014

Has this happened to you? You are in your office toiling away in the tax trenches when a colleague down the street who works the offshore cases sends you an e-mail: “I’m sending over an OVDP client. He has a problem and I can’t represent him anymore.” Eventually the client sits in your office and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 12, 2014

Historically, IRS 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 for purposes […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 08, 2014

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets.[i] The streamlined procedures require the filing of original or amended tax returns reporting not only for whatever foreign source income […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 05, 2014

There are various audit and investigative techniques available to corroborate or refute a taxpayer’s claim about their business operations or nature of doing business. 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 […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 31, 2014

The Internal Revenue Manual (IRM) contains a Penalty Handbook intended to serve as the foundation for addressing the administration of penalties by the IRS. It is the “one source of authority for the administration of penalties. . .”[1] and provides a “fair, consistent, and comprehensive approach to penalty administration.” As such, the IRM is often […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 02, 2014

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets. The streamlined procedures require the filing of original (for non-residents) or amended (for residents) tax returns. Such tax returns must not […] Read More…