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STEVEN TOSCHER quoted in Tax Notes Article on Appointment of National Fraud Counsel

Longtime IRS attorney Carolyn Schenck has been selected to advise the agency’s new fraud enforcement program. Steven Toscher of Hochman Salkin Toscher Perez PC said Schenck’s appointment suggests a “continued and sustained commitment by the IRS to detect and deter tax fraud,” and that the appointment of Schenck, along with Rowe and O’Dell, will yield […] Read More…

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9th Circuit Confirms Plea Agreements Are Worth the Paper They’re Printed On By EVAN J. DAVIS

Most federal criminal cases end in a written plea agreement, and tax cases are no exception. In plea negotiations, prosecutors wield enormous power and can effectively dictate the terms to most defendants. The plea agreements are largely district-specific, boilerplate documents that even individual prosecutors can’t modify outside of the factual basis, minor adjustments to appellate […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to speak on IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming Strafford webinar on IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives, Tuesday, May 26, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. All tax practitioners need to […] Read More…

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STEVEN TOSCHER quoted in Tax Notes Regarding Recent PPP Prosecutions

Applicants who clearly lied in their applications for the Paycheck Protection Program’s (PPP) tax-free forgivable loans will make better targets for criminal investigation than those who don’t fit lawmakers’ ideas of the program’s intended beneficiaries. “I’m sure there are some blatantly false [statements on PPP loan applications], and I think that is where it’s going […] Read More…

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DENNIS PEREZ, MICHEL STEIN, ROBERT HORWITZ and SANDRA BROWN to speak on What Professionals Need to Know About PPP Loans and Employee Retention Credit

We are pleased to announce that three of our principals Dennis Perez, Michel Stein, Robert Horwitz and Sandra Brown will be speaking at the upcoming CalCPA webinar on What Professionals Need to Know About PPP Loans and Employee Retention Credit, Tuesday, May 19, 2020, 9:00 a.m. – 10:00 a.m. PST. The panel will discuss the tax […] Read More…

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There’s No Getting Around the Pay First, Litigate Later Rule for California Taxes by ROBERT HORWITZ

Most tax professionals are familiar with the Supreme Court’s Flora decision: a taxpayer has to pay in full a tax assessment plus penalties and interest before you can bring a refund suit.  California has had a similar rule, which has been part of the California Constitution since 1913.  Article XIII, sec. 32 of the California […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to speak on Captive Insurance Companies: Where Are We Going After the IRS Victories

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Cory Stigile will be speaking at the upcoming CPAacademy webinar on Captive Insurance Companies: Where Are We Going After the IRS Victories, Tuesday, June 30 2020, 1:00 pm PDT; 12:00 PST. The Internal Revenue Service (IRS) began sending contact letters […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and JONATHAN KALINSKI to speak on Taxation of Cannabis: Overcoming Tax Challenges in Marijuana Business Operations, Key Planning Techniques

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Jonathan Kalinski will be speaking at the upcoming Strafford webinar on Taxation of Cannabis: Overcoming Tax Challenges in Marijuana Business Operations, Key Planning Techniques, Thursday, June 18, 2020, 1:00 pm-2:30 pm EST, 10:00 am-11:30 am PST. This CLE/CPE webinar will provide […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to speak on Developments in Cryptocurrency – Reporting and Enforcement

We are pleased to announce that three of our principals Steven Toscher, Michel Stein and Sandra Brown will be speaking at the upcoming CPAacademy webinar on Developments in Cryptocurrency – Reporting and Enforcement, Wednesday, June 3, 2020, 3:00 pm PDT; 2:00 PST. The Internal Revenue Service (IRS) launched a “soft letter” campaign advising taxpayers believed […] Read More…

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STEVEN TOSCHER quoted in Tax Notes on Conservation Easement Tax Enforcement

Enacting a safe harbor for conservation easement valuations may be an ideal way to reconcile Congress’s desire to preserve land with the IRS’s concerns about valuation abuse, according to a practitioner. “In tax law, you can’t help but be involved in valuations,” said Steven Toscher of Hochman Salkin Toscher Perez PC. “But it’s not an exact science, and sometimes it can […] Read More…

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This May Be a Very Good Time to Consider a Voluntary Disclosure By SANDRA R. BROWN

For decades, the Internal Revenue Service (“IRS”) has maintained a voluntary disclosure policy which provides an opportunity for taxpayers to come forward and disclose their noncompliance with the tax laws with the primary incentive being that, in almost all cases, the taxpayer will avoid criminal prosecution. The IRS made some significant announcements recently that could […] Read More…

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Beware Running of Pending Statute of Limitations When Seeking Taxpayer Advocate Service Assistance – IRS Gives Notice of Nonacquiescence with Court of Appeals’ Decision that Found Seeking Help from Taxpayer Advocate Service Tolls Time To File Claim to Challenge Wrongful Levy By SANDRA R. BROWN

The Internal Revenue Service (“IRS”) has recently provided notice that it will, in large part, not follow the adverse decision issued by the Fifth Circuit Court of Appeals in Rothkamm v. United States[i] which found that seeking help from the Taxpayer Advocate Service (“TAS”) tolled the time limits under IRC § 6343(b) for the filing […] Read More…

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