TAXLITIGATOR Blog

ABA 39th Annual National Institute on Criminal Tax Fraud & Tax Controversy

I am very pleased to announce this year’s ABA National Institute on Criminal Tax Fraud & Tax Controversy to be held December 12-14, 2022 at Caesar’s Palace in Las Vegas, Nevada. I am honored again to be serving as Co-Chair with Kathryn Keneally. We look forward to the best programs in the nation on civil […] Read More…

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JONATHAN KALINSKI to Speak at Upcoming Los Angeles Estate Planning Council Seminar

We are pleased to announce that Jonathan Kalinski will be speaking at the upcoming Los Angeles Estate Planning Council seminar “Lawyers, Guns & Cryptocurrency,” Wednesday, November 16, 2022, 11:45 a.m. – 1:30 p.m. (PST) at the The California Club (538 S Flower St, Los Angeles, CA 90071). This seminar will address the challenges of administering estates that contain […] Read More…

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SANDRA BROWN Quoted in Forbes on IRS Loses Battle In War On Conservation Easements

Sandra Brown was recently quoted in Forbes on the recent decision in Green Valley Investors, LLC v. Commissioner, 159 T.C. No. 5 (November 9, 2022), where the United  States Tax Court invalidated IRS Notice 2017-10, pertaining to the listing and reporting requirements for syndicated  conservation easements.   Check out the great article–“IRS Loses Battle in War […] Read More…

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UCLA 38th Annual Tax Controversy Institute

We are very pleased to report that the 38th Annual UCLA Extension Tax Controversy Institute which took place on October 27 at the Beverly Hills Hotel was a resounding success. After two years of video conferences, the annual gathering of top Government representatives and private practitioners was back in person and in full force.  We want to thank the great staff of […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to Speak at Upcoming Spidell Webinar

We are pleased to announce that Steven Toscher, Michel Stein and Evan Davis will be speaking at the upcoming Spidell webinar “Cryptocurrency Tax Compliance in the Rollercoaster Bitcoin World,” Tuesday, November 15, 2022, 10:00 a.m. – 12:00 p.m. (PST). This course will provide tax counsel, accountants, and other advisers with a critical first look at recent IRS enforcement actions on […] Read More…

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ROBERT HORWITZ Receives JOANNE M. GARVEY AWARD

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 MICHEL STEIN to Speak at Upcoming National Business Institute Webinar

We are pleased to announce that Steven Toscher, Sandra Brown and Michel Stein will be speaking at the upcoming NBI webinar “IRS Enforcement Priorities Update (Under the Inflation Reduction Act),” Thursday, November 17, 2022, 9:00 a.m. – 10:00 a.m. (PST). The Inflation Reduction Act of 2022 (IRA) increased the IRS’s budget by almost $80 billion over the next 10 years, […] Read More…

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STEVEN TOSCHER, ROBERT HORWITZ and LACEY STRACHAN to Speak at Upcoming Spidell Webinar

We are pleased to announce that Steven Toscher, Robert Horwitz and Lacey Strachan will be speaking at the upcoming Spidell webinar “Estate and Gift Tax Audits,” Monday, November 7, 2022, 10:00 a.m. – 12:00 p.m. (PST). Practical advice for preparing for and resolving estate and gift tax issues with the IRS. Topics covered include: Preparing an estate or gift tax […] Read More…

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EDWARD ROBBINS, JR. and EVAN DAVIS to Speak at Upcoming Hawaii Tax Institute

We are pleased to announce that Edward Robbins, Jr. and Evan Davis will be speaking on the following topics at the upcoming Hawaii Tax Institute 59th Annual In-Person Conference being held at the Sheraton Waikiki, November 6-10, 2022. Edward Robbins, Jr.November 9, 2022“FBAR Reporting: Trends, Pitfalls, and Enforcement. What You Need to Discuss With Your Clients” Evan DavisNovember 10, […] Read More…

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MICHEL STEIN, EDWARD ROBBINS and SANDRA BROWN to Speak at Upcoming Spidell Webinar

We are pleased to announce that Michel Stein, Edward Robbins and Sandra Brown will be speaking at the upcoming Spidell webinar “Form 8300 Reporting/Cash Intensive Business Audits,” Friday, October 21, 2022, 10:00 a.m. – 12:00 p.m. (PST). The law requires that trades and businesses report cash payments of more than $10,000 to the federal government by filing Form 8300. This […] Read More…

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Journal of Tax Practice and Procedure – First Circuit Reliance in a Cryptocurrency Summons Enforcement Case Widens the Crack Created in the Anti-Injunction Act by CIC Services, LLC, v IRS by SANDRA BROWN and GARY MARKARIAN

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 of […] Read More…

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SANDRA BROWN to Speak at Upcoming Freeman Law International Tax Symposium

We are pleased to announce that Sandra Brown will be speaking at the upcoming Freeman webinar “FBAR: Current Legal Developments and Challenges,” Thursday, October 20, 2022, 1:10 p.m. – 2:00 p.m. (CST). The Supreme Court has finally granted certiorari to look at the non-willful FBAR penalties imposed by the IRS. Originally enacted in the 1970s, the Bank Secrecy Act’s FBAR […] Read More…

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