TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, June 05, 2026

The California Office of Tax Appeals (OTA) recently published two precedential sales tax pending decisions that, in practical terms, answered questions regarding personal liability, penalties, and interest abatements for unpaid sales tax. Part I focused on the Appeal of Sundown Entertainment Group, Inc., 2026-OTA-225P. There, the OTA sustained a large sales tax determination after the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 04, 2026

We are pleased to announce that Steven Toscher, Robert S. Horwitz, and Cory Stigile will be speaking at the upcoming Barbri webinar on CDTFA Sales and Use Tax Examinations: High-Risk S&U Tax Issues, California S&U Tax Audits, Preparing for CDTFA Scrutiny on Tuesday, June 9, 2026, 10:00 a.m. – 11:50 a.m. (PST). This webinar will […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, May 29, 2026

The California Office of Tax Appeals (OTA) recently published two precedential sales tax pending decisions that, in practical terms, answered questions regarding personal liability, penalties, and interest abatements for unpaid sales tax. Part I focuses on the Appeal of Sundown Entertainment Group, Inc., 2026-OTA-225P. Here, the OTA sustained a large sales tax determination after the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, May 28, 2026

We are pleased to announce that Melissa Briggs along with Lisa Nelson (Taylor Nelson Amitrano, LLP)will be speaking at the upcoming Annual Meeting & Education Conference, at Holiday Inn, Missoula, Montana, June 26, 2026 from 9:45 a.m. – 11:00 a.m. (MT) on Best Practices for Securing IRS Refunds. Melissa and Lisa will discuss IRS Claims […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 27, 2026

On April 6, 2026, the FBI released its 2025 Internet Crime Report, which states that in 2025 the Internet Crime Complaint Center received 1,088,597 complaints of cyber-enabled crimes that cost Americans almost $21 billion. The largest number of complaints involved cryptocurrency, where there were 181,565 complaints involving more than $11 billion in losses. Click Here for […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 26, 2026

The Department of Justice rescheduled state licensed medical cannabis from Schedule I to Schedule III. The order also established a registration system. This change raises many questions, including tax and especially the application of IRC sec. 280E. Principal Jonathan Kalinski collaborated with former AUSA and current Professor Julie Werner-Simon on a featured article in the Cannabis Business Times […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, May 14, 2026

A California nonresident is taxable by California on income earned from sources in California. Where two or more commonly owned companies carry on a trade or business within and outside of California, the net income is allocated and apportioned between California and other states under the Uniform Division of Income for Tax Purposes Act (“UDITPA”). In Appeal […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, April 30, 2026

We are pleased to announce that two of our Principals will be speaking at the upcoming ABA Tax Section 2026 May Tax Meeting, May 7-9, 2026, at the Marriott Marquis Washington, D.C., on the following key topics: On the Front Lines: Criminal Tax Enforcement Priorities, Investigations, and Prosecutions: May 9th at 9:30 a.m (EST) Sandra R. Brown, along […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, April 24, 2026

We are pleased to announce that Dennis Perez, Michel R. Stein, and Robert S. Horwitz will be speaking at the upcoming Barbri webinar on Navigating Federal and State Tax Residency Issues: IRS Examination Guidance, State Regulations, and Remote Workers on Thursday, April 30, 2026, 10:00 a.m. – 11:30 a.m. (PST). This webinar will guide tax […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, April 21, 2026

We are pleased to announce that Michel R. Stein, Robert S. Horwitz and Jonathan Kalinski will be speaking at the upcoming CalCPA webinar on Effectively Managing State Income Tax Examinations, Protests and Appeals Before the FTB on Tuesday, April 21, 2026, 9:00 a.m. – 10:30 p.m. (PST). Successfully navigating a California income tax controversy requires […] Read More…

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…

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…