TAXLITIGATOR Blog
STEVEN TOSCHER Quoted in Tax Notes on Foreign Reporting Penalty Case Tackles Novel Constitutional Issues
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Thursday, April 18, 2024
Steven Toscher was quoted in a Tax Notes Article on the Tax Court’s recent decision in Mukhi v. Commissioner concerning an 8th Amendment challenge to foreign trust information reporting penalties. While the Tax Court rejected the 8th Amendment challenge to foreign trust information penalties, the controversy and arguments will continue. As noted by Steve …. “. . . the government […] Read More…
Read MoreSteven R. Toscher to Receive the ABA Tax Section Jules Ritholz Merit Award – May 3, 2024
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, April 08, 2024
We are pleased to announce that Steven Toscher will be receiving the prestigious Jules Ritholz Memorial Merit Award presented by the Civil and Criminal Tax Penalties Committee of the Taxation Section of the American Bar Association. The Award is being presented at the May meeting of the Taxation Section taking place May 2nd to 4th in […] Read More…
Read MoreCleared for Take Off: The IRS’s New Business Aircraft Campaign Poised to Examine Large Corporations, Large Partnerships, and High-Income Individual Filers by Michel R. Stein and Michael Greenwade
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, April 02, 2024
Using a portion of the tens of billions of dollars now set aside for enhanced IRS enforcement under the Inflation Reduction Act of 2022 (the “IRA”),[1] the IRS announced a new campaign under its Large Business & International (LB&I) Division: The Business Aircraft Campaign (the “BAC”) on February 21, 2024.[2] In an effort to ensure tax […] Read More…
Read MoreIRS Announces New Initiative Targeting High-Income Individuals Who Did Not File A Tax Return – A Risk of Criminal Liability by Steve Toscher, Sandra Brown, Evan Davis and Luke Ryan
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, March 28, 2024
On February 29, 2024, the IRS announced a new initiative targeting approximately 125,000 high-income taxpayers who have failed to file federal income tax returns since 2017. With funding from the 2022 Inflation Reduction Act, the IRS will send compliance letters to these individuals, including over 25,000 letters to individuals with incomes above $1 million and over […] Read More…
Read MoreMICHEL STEIN to Speak at Upcoming ABA Webinar
Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, March 21, 2024
We are pleased to announce that Michel R. Stein will be speaking at the upcoming ABA Section of Real Property, Trust & Estates Law webinar on the on the topic of “IRS Exams for High Wealth Individuals and Partnerships” on Tuesday, April 2, 2024, 10:00 a.m. – 11:30 a.m. (PST), along with co-panelists, Eric Cirelli (IRS […] Read More…
Read MoreSave the Date – UCLA 40th Annual Tax Controversy Conference – October 24, 2024
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 20, 2024
Dear Colleague- We cannot believe that it is March already and it’s time to Save the Date for the 2024 UCLA Extension Tax Controversy Institute, which will be held this year on October 24, 2024 at the Beverly Hills Hotel. It will be the 40th Anniversary of the Institute and you will not want to miss […] Read More…
Read MoreSTEVEN TOSCHER, SANDRA BROWN and EVAN DAVIS to Speak at Upcoming CalCPA Webinar – Updated
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 13, 2024
We are pleased to announce that Steven Toscher, Evan Davis, and Sandra Brown will be speaking at the upcoming CalCPA webinar “New Corporate Transparency Act: The World is Changing” Tuesday, March 19, 2024, 9:00 a.m. – 10:00 a.m. (PST). On January 1, 2021, Congress enacted the National Defense Authorization Act for Fiscal Year 2021 (NDAA). Contained within the […] Read More…
Read MoreMICHEL STEIN to Speak at Upcoming San Fernando Valley Bar Association Webinar
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 12, 2024
We are pleased to announce that Michel R. Stein will be speaking at the upcoming SVBA webinar “IRS Enforcement Priorities for 2024 and Beyond” Tuesday, March 19, 2024, 12:00 p.m. (PST). Michel Stein will lead a discussion on what tax practitioners can expect from the Internal Revenue Services’ audit priorities and enforcement action after the Inflation […] Read More…
Read MoreTaxpayers Take Note: A Fraudulent Return Preparer Means the Statute of Limitations on Assessment Never Ends by ROBERT HORWITZ
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, March 11, 2024
Each year the majority of taxpayers who retain the services of return preparers to navigate the complexities of the tax laws to ensure the filing of accurate returns are in good hands. However, countless numbers of taxpayers who look to others to assist in this often daunting task discover years later, when the IRS knocks, that […] Read More…
Read MoreTracking the ERC: Voluntary Disclosure Program Deadline Approaching and Other ERC Updates By SANDRA R. BROWN and HUNTER KEASTER
Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, March 06, 2024
The Employee Retention Credit (ERC) is a refundable tax credit created by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) in 2020 to help businesses negatively impacted by the COVID-19 pandemic maintain their payroll. The credit has very specific eligibility requirements including full or partial suspension of business operations because of government orders […] Read More…
Read MoreThe IRS Bolsters Its Crypto Expertise and Other Tax Enforcement Agencies May Not Be Far Behind By STEVEN TOSCHER, ROBERT HORWITZ and PHILIPP BEHRENDT
Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, March 05, 2024
The IRS has taken an important step to strengthen its understanding and oversight of the cryptocurrency space and may signal a bull market of tax enforcement in the crypto realm. The agency recently announced the hiring of two private sector experts as advisors – Sulolit “Raj” Mukherjee and Seth Wilks. Both individuals have extensive experience […] Read More…
Read MoreThawing the Ice: Landmark Indictment Signals New Era in Crypto Tax Enforcement by SANDRA R. BROWN and PHILIPP BEHRENDT
Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, March 04, 2024
What It’s About On February 7, the Justice Department announced a seven-count indictment against Frank Richard Ahlgren III, charging him with filing false tax returns and structuring transactions based on his cryptocurrency dealings between 2017 and 2019. Ahlgren faces three counts of filing false tax returns under 26 U.S.C. section 7206(1), related to underreporting or […] Read More…
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