TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 14, 2026

For taxpayers with potentially willful tax noncompliance, the IRS Voluntary Disclosure Practice (“VDP”) has always offered a metaphorical “carrot and stick” bargain: come forward before the government finds you, disclose the conduct, pay the tax and some penalties, and in return, substantially reduce the risk of criminal prosecution. In recent years, however, that bargain has […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, September 14, 2026

In a rare and welcomed victory for taxpayer rights and administrative fairness, the IRS has agreed to remove the willfulness checkbox from the next version of the Form 14457—the application form for the Voluntary Disclosure Practice (VDP). In addition, the program will make allowances not to preclude income derived from marijuana sales by changing its […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, September 09, 2026

Dear Colleague- The highly anticipated 2026 UCLA Extension Tax Controversy Conference is fast approaching, and this is an event you don’t want to miss! By registering now through the link below, you can gain invaluable insights through our distinguished keynote speakers, Emin Toro, a respected Judge of the United States Tax Court, and Jarod Koopman, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, September 04, 2026

Private aircraft have been on the tax authorities’ radar for some time. Now, quite literally, the radar may be doing the auditing. The Los Angeles Times reported this week that the Los Angeles County Assessor has sent hundreds of tax bills to private aircraft owners, including aircraft linked by a flight-tracking service to some of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, September 02, 2026

We are pleased to announce that Melissa Briggs will be speaking on Hot Topics in Tax Litigation at the upcoming Contra Costa County Bar Association webinar being held on Thursday, September 10, 2026, 12:00 p.m. – 1:00 p.m. (PST). A survey of some of the year’s most significant developments in tax controversy and litigation. Ms. Briggs […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 28, 2026

We are pleased to announce the publication of the 11th edition of the Internal Revenue Service Practice & Procedure Deskbook. The Deskbook is co-authored by Principal of the firm Edward M. Robbins, Jr. along with Thomas Greenaway (KPMG). The release of the Eleventh Edition of Internal Revenue Service Practice & Procedure Deskbook contains practical guidance […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 21, 2026

We are pleased to announce that Dennis Perez, Jonathan Kalinski and Sebastian Voth will be speaking at the upcoming Strafford/Barbri webinar on Resolving Federal and State Employment Tax Matters: Worker Classification on Tuesday, August 25, 2026, 10:00 a.m. – 11:50 a.m. (PST). The IRS is increasing enforcement against taxpayers who fail to comply with withholding […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 21, 2026

Marc Montano’s focus is on representation of clients in civil and criminal tax litigation and investigations. Mr. Montano joined the firm in 2026 while attending NYU Law School, where he received his LL.M. in Taxation. Mr. Montano has worked on a variety of matters focusing on tax controversy and litigation, criminal and civil fraud, including […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, August 20, 2026

Managing Principal Steven Toscher was interviewed for a CBS News Report on the administration’s enforcement regarding non-profit organizations. The article reflects increasing activity on many fronts including the Department of Justice and potential new Internal Revenue Service 990 Reporting requirements. Steve said that from a good governance perspective, he does not see a problem with requiring […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, August 19, 2026

We are pleased to announce that Melissa Briggs along with Justin Elanjian (Tax Managing Director, Frost Law), Lisa O. Nelson (Managing Partner, Taylor Nelson Amitrano) and Philip J. Wilson (Managing Director, CBIZ) will be speaking on Beyond Kwong: Refund Claims and Best Practices for Preserving Taxpayer Rights at the upcoming St. Louis Summer Tax Summit […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 14, 2026

Philipp Behrendt was recently quoted in “Crypto Theft, Tax Losses, and Recovery,” by Lee A. Sheppard, published in Tax Notes Federal, Volume 192, on August 10, 2026. The article examines the tax consequences of cryptocurrency theft and fraud, including the challenges victims face in establishing a deductible theft loss, demonstrating a profit motive, and proving […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, August 12, 2026

We are pleased to announce that Jonathan Kalinski and Sebastian Voth will be speaking at the upcoming CalCPA webinar on Employment Tax Resolving Federal and State Employment Tax Matters – Worker Classification on Tuesday, August 18, 2026, 9:00 a.m. – 10:30 a.m. (PST). The IRS is increasing enforcement against taxpayers who fail to comply with […] Read More…