Our Blog

If the Court Thinks You Preferred a “Lavish Lifestyle” Over Paying Taxes, You May Find the Tax Not Dischargeable in Bankruptcy (Unless You Live in the Ninth Circuit) by ROBERT S. HORWITZ

I recently blogged on the Eleventh Circuit’s decision in In re Shek rejecting First, Fifth and Tenth Circuit precedent that a late return filed two years or more before bankruptcy is not discharged.  Today I am blogging on another recent bankruptcy case, In re Harold, 2020 WL 709866 (B. Ct. M.D. Mich. 2/12/2020), which addressed […] Read More…

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High Income Non-Filers Are Back in Sights of the New Enforcement Minded IRS – by STEVEN TOSCHER and GARY MARKARIAN

On February 19, 2020, the IRS issued IR-2020-34, which states the IRS “will step up efforts to visit high-income taxpayers who in prior years have failed to timely file one or more of their tax returns.”  If the Commissioner of Internal Revenue Charles P. Rettig was speaking, he might say that high income taxpayers who […] Read More…

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Eleventh Circuit Creates Split in the Circuits on Issue of Whether a Later Return is a Return for Purposes of the Bankruptcy Code by ROBERT S. HORWITZ

Three types of tax debts are excepted from discharge in bankruptcy: First, those entitled to priority under sec. 507(a) of the Bankruptcy Code.  11 U.S.C. Sec. 523(a)(1)(A). Second, those with respect to which a return, if required, was not filed or was filed after it was last due and after two years before the date […] Read More…

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MICHEL STEIN to speak on Update on the Taxation of Cryptocurrency Transactions

We are pleased to announce that Michel Stein will be speaking at the upcoming SFVBA Taxation Law Section Seminar on Update on the Taxation of Cryptocurrency Transactions, Tuesday, February 18, 2020, 12:00 pm-1:15 pm. Mr. Stein will discuss new IRS pronouncement and recent developments regarding taxation of cryptocurrency transaction For full programming details Click Here.   […] Read More…

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American College of Tax Counsel Elects New Fellow MICHEL STEIN

We are pleased to announce that Michel Stein has been elected as Fellow by the American College of Tax Counsel. Michel, a principal of our firm, joined us in 1998, after a prestigious position as an Attorney-Advisor at the United States Tax Court. He holds an LL.M in Taxation from New York University and is a former Chair […] Read More…

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Favorable California Office of Tax Appeals Drop and Swap Decision Stands by CORY STIGILE

In 2018, Robert Horwitz posted a blog on the Appeal of Mitchell (8/2/2018), a favorable Office of Tax Appeals Opinion (the “Opinion”) that approved a “drop and swap” transaction. The FTB filed a Petition for Rehearing, which has been pending until last week when a majority Opinion on Petition for Rehearing concluded that the FTB […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to speak on Section 199A Implementation and IRS Examination Issues: Critical QBI Issues for Individual and Business Taxpayers

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 Section 199A Implementation and IRS Examination Issues: Critical QBI Issues for Individual and Business Taxpayers, Tuesday, February 11, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will guide tax professionals […] Read More…

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STEVEN TOSCHER to speak at the Federal Bar Association 44th Annual Tax Law Conference, Ronald Reagan Building and International Trade Center, Washington, D.C.

We are pleased to announce that Steven Toscher, will be speaking along with Sarah E. Paul, Eversheds Sutherland, Niles Elber, Caplin & Drysdale, Thomas Curteman, Jr., Office of Chief Counsel, IRS and Hank Kea, Field Collection Operations, IRS on “Avoiding or Not Avoiding Evasion of Payment Prosecutions & the Civil Aftermath” at this year’s Federal […] Read More…

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SANDRA BROWN to speak at ABA Midyear Tax Meeting, Boca Raton Resort and Club, Florida

We are pleased to announce that Sandra Brown, will be moderating the panel  along with Jason B. Freeman, Freeman Law, Victor Jaramillo, Caplin & Drysdale, and  John Siddons, Supervisory Special Agent, Internal Revenue Service, Criminal Investigation on “A Client with Cryptocurrency Just Call – What Now?” at this year’s ABA Midyear Tax Meeting, Saturday, February […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to speak on Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Advisers

We are pleased to announce that two of our principals Steven Toscher and Michel Stein will be speaking at the upcoming Strafford webinar on Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Advisers, March 31, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will guide tax professionals and advisers on critical issues relating […] Read More…

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Estate Notches Rare Win over IRS in Penalty Refund Suit by SANDRA BROWN and TENZING TUNDEN

Enforcement and compliance is a top priority of the Internal Revenue Service (“IRS”). The IRS has 150 penalties at its disposal to assist in its stated goals of enforcement and obtaining compliance with the tax laws of the United States. Many of these penalties can be assessed not only against taxpayers but also against tax […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to speak New Cryptocurrency Guidance: Identifying Units, Hard Forks and Airdrops

We are pleased to announce that three of our principals will be speaking at the upcoming Strafford webinar on New Cryptocurrency Guidance: Identifying Units, Hard Forks and Airdrops, January 14, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will discuss recently released IRS Revenue Ruling 2019-24 and the updated FAQs regarding taxation of cryptocurrency. With […] Read More…

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