TAXLITIGATOR Blog
The California Office of Tax Appeals Holds that Taxpayers Were Entitled to Nonrecognition of Gain Due to an Involuntary Conversion by Robert Horwitz
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Friday, April 17, 2026
Internal Revenue Code (“IRC”) sec. 1033 allows a taxpayer to elect to defer gain from an involuntary conversion of property if the taxpayer “purchases other property similar to or related in service or use to the property so converted, or purchases stock in the acquisition of control of a corporation owning such property.” In a […] Read More…
Read MoreDirty Dozen Tax Scams for 2026: IRS Reminds Taxpayers to Watch Out for Dangerous Threats by Sandra R. Brown
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, April 02, 2026
Since 2002, typically during the annual tax filing season, the IRS has released its “Dirty Dozen” list to warn taxpayers and tax practitioners alike of various tax scams as well as abusive transactions that the Service will be focused on in the coming year. The list has evolved over the past 20 years but often […] Read More…
Read MoreWhat Does DOJ’s New Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy Mean for Corporate Criminal Tax Disclosures? by Sandra R. Brown
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, March 30, 2026
On March 10, 2026, the Department of Justice (DOJ) launched its first department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), standardizing how prosecutors handle corporate criminal cases. This move consolidates decades of subject matter-specific guidance into one unified framework for how the DOJ will handle all corporate criminal cases, with the exception of antitrust violations under […] Read More…
Read MoreMichel R. Stein, Robert S. Horwitz & Melissa Briggs to Speak at Upcoming Spidell Webinar on Using Internal Revenue Code Sec. 7508A to Reduce Your Client’s Liability for Covid-Era Interest & Penalties
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 18, 2026
We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Melissa Briggs will be speaking at the upcoming Spidell webinar on Using IRC §7508A to Reduce Your Client’s Liability for Covid-Era Interest & Penalties on Thursday, March 26, 2026, 10:00 a.m. – 12:00 p.m. (PST). Please join us to: Click Here to […] Read More…
Read MoreJournal of Tax Practice and Procedure – The Strategic Use of FOIA in Your Tax Practice Sebastian Voth
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 11, 2026
We are pleased to announce that Sebastian Voth‘s article, The Strategic Use of FOIA in Your Tax Practice, was published in the Winter 2025 issue of the Journal of Tax Practice & Procedure. The article outlines the statutory framework of the Freedom of Information Act (FOIA) and provides guidance for handling FOIA requests in IRS […] Read More…
Read MoreWhat Is All the Hype About Covid-Related Interest? by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 04, 2026
On February 6, 2026, Western Digital Corp. filed a refund suit in the Court of Federal Claims seeking the refund of $20,764,747 of underpayment interest that accrued during the period of the federally declared disaster during Covid-19. Western Digital Corp. v. United States, No. 26-215. Richard Rubin reported on the case on February 16, in […] Read More…
Read MoreA Discussion of Learning Resources, Inc., in which the Supreme Court Struck Down the President’s Claim to Impose Tariffs at Will by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 03, 2026
You undoubtedly know by now that on Friday, February 20, 2026, the United States Supreme Court held that Pres. Trump does not have the authority under the International Emergency Economic Powers Act (IEEPA) to impose tariffs on imports. Not one to be deterred, Pres. Trump immediately announced the imposition of a 10% global tariff under […] Read More…
Read MoreMichel R. Stein and Cory Stigile to Speak at Upcoming Barbri Webinar on Navigating IRS Corporate and High-Income Taxpayer Audits
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, March 02, 2026
We are pleased to announce that Michel R. Stein and Cory Stigile along with Timothy Bilotta will be speaking at the upcoming Barbri webinar on Navigating IRS Corporate and High-Income Taxpayer Audits, on Wednesday, March 4, 2026, 10:00 a.m. – 11:30 a.m. (PST). We are honored to have Tim join us for the program. Tim is recently retired from […] Read More…
Read MoreSebastian Voth to Speak at Upcoming Barbri Webinar on the Economic Substance Doctrine: Withstanding IRS Challenges
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 25, 2026
We’re pleased to announce that Sebastian Voth along with Ed Froelich and Sam Hamer (McDermott, Will & Schulte) will be speaking at the upcoming Barbri webinar on Economic Substance Doctrine: Withstanding IRS Challenges on Thursday, March 5, 2026, 10:00 a.m. – 11:50 a.m. (PST). This webinar will review the economic substance doctrine (“ESD”) as it has […] Read More…
Read MoreSteven Toscher to Speak at Upcoming UCLA School of Law and Loyola School of Law 29th Annual Western Conference on Tax Exempt Organizations
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, February 23, 2026
We are pleased to announce that Steven Toscher will be speaking at the UCLA School of Law Lowell Milken Center for Philanthropy and Nonprofits and Loyola Law School 29th Annual Western Conference -Tax Exempt Organizations on Audits and Investigations, Friday, March 13,2026, 11:15 a.m. – 12:30 p.m. the California Endowment’s Center for Healthy Communities in Downtown […] Read More…
Read MoreThe California Office of Tax Appeals Hands Taxpayers a Partial Victory in a Like-Kind Exchange Case by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, February 20, 2026
Sec. 1031(a) of the Internal Revenue Code provides that no gain or loss is recognized when property held for productive use in a trade or business or for investment is exchanged for like-kind property to be held either for productive use in a trade or business or for investment. The purpose of section 1031 is […] Read More…
Read MoreThe California Supreme Court Says the Only Way to Challenge a Special Assessment of Property Tax is by Exhausting Administrative Remedies by Robert S. Horwitz
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, February 18, 2026
In 2008, California enacted the Property Assessed Clean Energy (“PACE”) Act that allows local governments to provide homeowners with financing for energy efficient home improvements. PACE allows local governments to fund their PACE programs by issuing bonds. The special assessment is assessed and collected “in the same manner and at the same time” as local […] Read More…
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