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STEVEN TOSCHER to Speak at Upcoming Orange County Estate Planning Council on When a Tax Case Goes Criminal – How to Avoid It and How to Deal with It – March 23, 2021

We are pleased to announce that Steven Toscher will be speaking at the upcoming Orange County Estate Planning Council webinar, “When a Tax Case Goes Criminal – How to Avoid It and How to Deal with It” on Tuesday, March 23, 2021, 4:45 p.m. – 6:00 p.m. (PST) While criminal tax prosecutions are at a […] Read More…

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STEVEN TOSCHER to Speak at Upcoming Florida Tax Institute on Increased IRS Exam Activity on High Wealth Taxpayers and Their Investment Structures – March 11, 2021

We are pleased to announce that Steven Toscher, along with Fred Murray, Deborah Palacheck and Clifford Scherwinski will be speaking at the upcoming Florida Tax Institute webinar, “Increased IRS Exam Activity on High Wealth Taxpayers and Their Investment Structures” on Thursday, March 11, 2021, 9:25 a.m. – 10:25 a.m. (PST). The IRS has again increased […] Read More…

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STEVEN TOSCHER and JONATHAN KALINSKI to Speak at Upcoming 45th Annual Federal Bar Association Tax Conference – March 5, 2021

We are pleased to announce that Steven Toscher and Jonathan Kalinski will be speaking at the  upcoming Federal Bar Association webinar: Steven Toscher – “Fraud Enforcement Office,”Friday, March 5, 2021, 11:30 a.m. – 12:30 p.m. (PST) Jonathan Kalinski – “Cannabis is Going National – Opportunities and Pifalls,Friday, March 5, 2021, 1:00 p.m. – 2:00 p.m. […] Read More…

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Eighth Circuit Rehears Coffey, but the Result Is the Same by Robert S. Horwitz

On December 16, 2020, the Eighth Circuit issued its opinion in Coffey v. Commissioner, holding that a tax return filed with the U.S. Virgin Islands Bureau of Internal Revenue (“VIBIR”) was not a filing with the IRS and, thus, the three year statute of limitations on assessment was not triggered. See https://www.taxlitigator.com/a-return-by-any-other-name-by-robert-s-horwitz/.  On February 10, […] Read More…

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Where is My “Tax Home” or Residency in a Post-COVID World? By Cory Stigile

In Soboyede v. Comm’r, T.C. Summary Opinion 2021-3, the Tax Court addressed whether the taxpayer’s travel expenses while performing legal work in Washington were incurred “while away from home” such that they could be deducted as ordinary and necessary travel expenses under IRC Section 162.   While this is a non-precedential opinion, it is a helpful […] Read More…

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The Corporate Transparency Act takes on Serious Tax Fraud: Say Goodbye to Not Disclosing Beneficial Owners of Entities by Sandra R. Brown and Michael Greenwade

Historically, most—if not all—states in the U.S. have not required the disclosure of the beneficial owners of corporations, LLCs, or similar entities formed under the laws of the State.[i]  However, with the enactment of the Corporate Transparency Act (CTA)[ii], as part of the 2021 National Defense Authorization Act, the non-disclosure approach has come to an […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to speak on Tax Reporting of Cryptocurrency: Calculating Basis, Income, and Gain

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming Strafford webinar, “Tax Reporting of Cryptocurrency: Calculating Basis, Income, and Gain, Determining Character of Gain and Basis in Mined Currency, Recognizing Filing Obligations and Prior Noncompliance” on Thursday, February 25, 2021, 10:00 a.m. – 11:50 a.m. […] Read More…

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Closing a Business May Result in Cancellation of Debt Income by Robert Horwitz and Tenzing Tunden

Many businesses either have closed or will be forced to close due to the lockdowns imposed during the COVID-19 pandemic, Closing a business can result in the loss of jobs, a loss of the business owner’s livelihood and the destruction of the business owner’s credit rating.  It can also have adverse tax consequences in the […] Read More…

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Journal of Accountancy – Enlist and Ally in TAS by CORY STIGILE

When the IRS’s processes are not working as they should, the Taxpayer Advocate Service (TAS) may be able to help. Sec. 7811 authorizes TAS to issue a taxpayer assistance order if the taxpayer is suffering, or about to suffer, a significant hardship as a result of the way the internal revenue laws are being administered. […] Read More…

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FinCEN Giveth With One Hand, Taketh With the Other by Confirming Virtual Currency Isn’t Reportable on an FBAR Form but Proposing to Require Reporting in Future and More Reporting by Money Services Businesses By EVAN J. DAVIS

The intersection of virtual currency with Bank Secrecy Act (BSA) and tax laws frequently results in a square peg, round hole problem.  All too often, regulators try to solve the problem as would a toddler, by pounding as hard as possible to make the square peg fit in the round hole.  Witness the IRS treating […] Read More…

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Time for Another IRS Reorganization by Steve Toscher and Robert S. Horwitz

Last week, the Commissioner issued the Taxpayer First Act (TFA) report to Congress. The report will establish the framework of the IRS for the next 20 year, with a goal of improved employee training, increased taxpayer accessibility and making the IRS a more technology-driven organization.  So what is the TFA and why is there a […] Read More…

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IRS Issues Regulations on the Non-Deduction of Fines and Penalties Under the New More Complex Section 162(f) by Robert S. Horwitz

Occasionally I feel sorry for the attorneys in IRS National Office who have to write regulations for the tax laws enacted by Congress.  Gone are the days when Congress had members who could write simple, logical statutes, like the original sec. 162(f), enacted in 1969: No deduction shall be allowed under subsection (a) for any […] Read More…

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