TAXLITIGATOR Blog

EVAN DAVIS Quoted in Law360 on Justices to Review Firm’s Bid to Shield Client Tax Comms

The U.S. Supreme Court said Monday it will consider a law firm’s bid to shield client communications from grand jury subpoenas seeking documents on its tax advice in a case concerning the scope of attorney-client privilege over mixed-use legal advice. In a statement, Evan J. Davis of Hochman Salkin Toscher Perez PC, one of the […] Read More…

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EVAN DAVIS Quoted in Thomson Reuters Transparency Groups, Tax Pros Differ on Impact of Ownership Reporting Rules

Evan Davis, a veteran tax litigator with Hochman Salkin Toscher Perez PC, predicted that existing businesses, particularly limited liability companies, will find adhering to the beneficial ownership regs to be “a herculean task and will result in far less than 100% compliance.” He said many clients already fail to take the basic steps to maintain […] 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 “Handling Cannabis Tax Examinations: Sec. 280E, Audits, IRS Guidance,” Tuesday, October 11, 2022, 10:00 a.m. – 11:30 a.m. (PST). The sale and distribution of cannabis for recreational or medical use is a powerful economic engine generating billions in annual […] Read More…

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ROBERT HORWITZ to Receive the Joanne M. Garvey Award from the California Lawyers Association 2022 Tax Bar and Tax Policy Conference

We are very pleased to announce that our friend and partner Robert Horwitz has been recognized for his outstanding contributions in the field of taxation by the California Lawyers Association 2022 Annual Meeting of the Tax Bar and Tax Policy Conference, November 2-4, 2022. Robert has over 40 years of experience as a tax attorney specializing […] Read More…

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STEVEN TOSCHER, SANDRA BROWN and EVAN DAVIS to Speak at Upcoming Spidell Webinar

We are pleased to announce that Steven Toscher, Sandra Brown and Evan Davis will be speaking at the upcoming Spidell webinar “New Corporate Transparency Act: The World is Changing,” Friday, October 7, 2022, 10:00 a.m. – 12:00 p.m. (PST). On January 1, 2021, Congress enacted the National Defense Authorization Act for Fiscal Year 2021 (NDAA). Contained within the NDAA is the Anti-Money […] Read More…

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DENNIS PEREZ, SANDRA BROWN and CORY STIGILE to Speak at Upcoming Spidell Webinar

We are pleased to announce that Dennis Perez, Sandra Brown and Cory Stigile will be speaking at the upcoming Spidell webinar “Research and Development Tax Credits: IRS Scrutiny of Qualified Research Activity and Related Expenses,” Thursday, September 29, 2022, 10:00 a.m. – 12:00 p.m. (PST). Research and development (R&D) is the lifeblood of a growing and prosperous economy, and many […] Read More…

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STEVEN TOSCHER to Speak at Upcoming CSTC Webinar

We are pleased to announce that Steven Toscher will be speaking at the upcoming CSTC 2022 Tax Forum Orange County South Chapter seminar at The Hills Hotel, Laguna Hills on “Cryptocurrency Tax Compliance: Tax Filing Requirements; Managing IRS Examinations,” Friday, September 16, 2022, 1:00 p.m. – 2:50 p.m. (PST). This course will provide tax counsel, accountants, and other advisers with a critical […] Read More…

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First Circuit in a Cryptocurrency Summons Enforcement Case Widens the Crack Created in the Anti-Injunction Act by CIC Services, LLC, v IRS
By Sandra R. Brown
[i] and Gary Markarian[ii]

Introduction It was a long-held belief that the Anti-Injunction Act barred Taxpayers from maintaining any lawsuit that had the effect of interfering with the assessment or collection of any tax. However, the recent Supreme Court decision in CIC Services created a crack in the Government’s use of the Anti-Injunction Act to dismiss cases for lack […] Read More…

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PHILIPP BEHRENDT to Speak at Upcoming Beverly Hills Bar Webinar

We are pleased to announce that Philipp Behrendt, along with LaVonne Lawson, Richard Gano and Michele F.L. Weiss will be speaking at the upcoming webinar at the Beverly Hills Bar Association on “Tax Impacts of the Inflation Reduction Act,” Tuesday, August 30, 2022, 12:30 p.m. – 1:30 p.m. (PST). President Biden recently signed The Inflation Reduction Act into law. The Act contains numerous tax provisions. […] Read More…

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Treece Financial Services Group v. Commissioner – The Broad Sweep of Tax Court Jurisdiction By: STEVEN TOSCHER, MICHEL STEIN and PHILIPP BEHRENDT

The Tax Court’s jurisdiction has been expanding over the years, both by legislation and rulings designed to make sure that taxpayers have adequate remedies.. This is the message in Treece Financial Services Group v. Commissioner, 158 T.C. No. 6, as well as the related opinion Treece Investment Advisory Corp. v. Comm’r, T.C. Memo 2022-38 (both […] Read More…

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SANDRA BROWN to Speak at Upcoming 39th Symposium on Economic Crime

We are pleased to announce that Sandra R. Brown will be speaking on upcoming seminars at the 39th Symposium on Economic Crime – Jesus College, University of Cambridge, being held at Jesus College, a College within the University of Cambridge, Sept. 4–11, 2022. Sandra will be participating on a panel entitled “Getting Your House in Order – Conducting Internal Investigation Into […] Read More…

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MICHEL STEIN to Speak at Upcoming CPA Academy Webinar

We are pleased to announce that Michel Stein along with Phillip Colasanto, Caroline Ciraolo and Daniel Price, will be speaking at the upcoming CPA Academy on “Coming in From the Cold: the Future of Voluntary Disclosures” on Tuesday, August 23, 2022, 2:00 p.m. – 3:00 p.m. (PST). For more than 70 years, the IRS maintained a voluntary disclosure policy designed to encourage […] Read More…

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