TAXLITIGATOR Blog

The Supreme Court Deals IRS a Losing Hand in FBAR Non-Willful Penalty Case by ROBERT HORWITZ

The Supreme Court Deals IRS a Losing Hand in FBAR Non-Willful Penalty Case by ROBERT HORWITZ

On February 28, 2023, the Supreme Court issued its opinion in Bittner v. United States, ___ U.S. ___, 143 S.Ct. 713, 2023 WL 2247233, holding that the non-willful FBAR penalty is applied per annual report and not per account. For the past few years, the IRS has taken the position that it could impose a separate […] Read More…

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Warning to Tax Professionals:  Use Care When Reviewing Clients’ Employee Retention Credit Positions by CORY STIGILE

Warning to Tax Professionals:  Use Care When Reviewing Clients’ Employee Retention Credit Positions by CORY STIGILE

On March 7, 2023, the IRS Office of Professional Responsibility (“OPR”) issued an OPR Alert titled Professional Responsibility and the Employee Retention Credit. This OPR bulletin (Issue Number: 2023-02) (the “OPR Alert”), was issued on the same day the IRS issued IR-2023-40, which renewed an October warning to employers about certain third-party advisors in the […] Read More…

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Tierra Del Sol Foundation – 16th Annual Charity Golf Tournament

Tierra Del Sol Foundation – 16th Annual Charity Golf Tournament

Help us celebrate our 16th Annual “Tee Off For Tierra!” Charity Golf Tournament, benefiting the people with developmental disabilities that Tierra empowers each day through Workforce Development, College to Career and Careers in the Arts. This year’s tournament will take place at North Ranch Country Club in Westlake Village. Registration fees include cart, swag bag, […] Read More…

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CORY STIGILE to Speak at Upcoming Orange County Bar Association Webinar

CORY STIGILE to Speak at Upcoming Orange County Bar Association Webinar

We are pleased to announce that Cory Stigile will be speaking at the upcoming OCBA webinar “Internal Revenue Service Scrutiny of the ERC,” Thursday, March 9, 2023, 11:00 a.m. – 12:00 p.m. (PST). This presentation will cover practical considerations for attorneys handling IRS examinations of ERC reported positions. Among other things, attendees will learn about ERC requirements, IRS scrutiny, […] Read More…

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Hochman Salkin Toscher Perez P.C. Recognized in Forbes and Fortune as Southern California Leaders in Law

Hochman Salkin Toscher Perez P.C. Recognized in  Forbes and Fortune as Southern California Leaders in Law

We are very pleased to announce that we are being featured this month in Forbes and Fortune magazines as leaders in the Southern California legal community. The magazine article and interview focuses on the long history and leadership of our firm specializing in civil and criminal tax controversy and litigation. We are honored to carry on […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to Speak at Upcoming CSTC Webinar

STEVEN TOSCHER and MICHEL STEIN to Speak at Upcoming CSTC Webinar

We are pleased to announce that Steven Toscher and Michel Stein will be speaking at the upcoming CSTC webinar “Cryptocurrency Tax Compliance: Tax Filing Requirements, Managing IRS Examinations,” Wednesday, March 1, 2023, 6:00 p.m. – 8:00 p.m. (PST). The program will provide tax advisers and compliance professionals with a practical look at IRS guidance to calculating and reporting income […] Read More…

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Hochman Salkin Toscher Perez P.C. Attorneys Recognized by 2023 Super Lawyers

Hochman Salkin Toscher Perez P.C. Attorneys Recognized by 2023 Super Lawyers

We are pleased to announce that 10 of our principals have been selected to the 2023 Southern California Super Lawyers. Attorneys selected as Super Lawyers are among the top five percent of Southern California’s licensed attorneys. Southern California Super Lawyers Magazine recognizes outstanding attorneys in more than 70 areas of practice using a rigorous, multiphase selection process that […] Read More…

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Hochman Salkin Toscher Perez P.C. Attorneys Recognized by 2023 Super Lawyers in Taxation

Hochman Salkin Toscher Perez P.C. Attorneys Recognized by 2023 Super Lawyers in Taxation

We are pleased to announce that 6 of our principals have been selected to the 2023 Southern California Super Lawyers List in the field of Taxation. Attorneys selected as Super Lawyers are among the top five percent of Southern California’s licensed attorneys. Southern California Super Lawyers Magazine recognizes outstanding attorneys in more than 70 areas of practice […] Read More…

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Don’t Forget the Requirement to File an Administrative Claim for the Refund of Taxes by PHILIPP BEHRENDT

On January 11, 2023, the United States District Court for the Western District of New York ruled on the case of United States v. Chen-Baker, Case. No. 1:22-cv-256. This case provides an important reminder of the importance for individuals or organizations in filing administrative claims against the government before suing the government.  This case involves […] Read More…

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MICHEL STEIN, SANDRA BROWN and EVAN DAVIS to Speak at Upcoming ABA Midyear 2023 Tax Meeting

MICHEL STEIN, SANDRA BROWN and EVAN DAVIS to Speak at Upcoming ABA Midyear 2023 Tax Meeting

Please join us February 9-11, 2023 for the ABA Midyear 2023 Meeting at the Hilton San Diego Bayfront. Our firm is proud to continue our participation. Meet with fellow tax practitioners and address the cutting-edge tax issues affecting all tax professionals. This three-day event includes discussions, networking opportunities led by the best tax professionals in the nation, covering various topics. […] Read More…

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STEVEN TOSCHER, SANDRA BROWN and JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar

We are pleased to announce that Steven Toscher , Sandra Brown and Jonathan Kalinski will be speaking at the upcoming Strafford webinar “Taxation of Cannabis: Overcoming Tax Challenges in Cannabis Business Operations, Key Planning Techniques,” Tuesday, January 17, 2023, 10:00 a.m. – 11:30 a.m. (PST). The sale and distribution of cannabis for recreational or medical use has become a […] Read More…

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California Board of Legal Specialization of the State Bar of California Recognizes Our Lawyers

California Board of Legal Specialization of the State Bar of California Recognizes Our Lawyers

We congratulate the lawyers at our firm who have been honored by the California Board of Legal Specialization of the State Bar of California with acknowledgment of at least 20 years of continued professional participation and advancement as Certified Specialists in Taxation Law HSTP is proud to encourage its lawyers to seek and maintain professional […] Read More…

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