TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, August 28, 2023

We are pleased to announce that Michel Stein, Edward Robbins, Jr. and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process” on Wednesday, September 6, 2023 from 10:00 a.m. – 11:30 a.m. (PST). The IRS employs strict standards for determining whether a taxpayer qualifies for penalty […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 22, 2023

We are pleased to announce that Sandra R. Brown will be speaking on upcoming seminars at the 40th Symposium on Economic Crime – Jesus College, University of Cambridge, being held at Jesus College, a College within the University of Cambridge, September 3–10, 2023. Sandra will be participating on the following panels Recent United States initiatives to enforce integrity Tuesday, September 4, 2023, 4:15 […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 15, 2023

This column summarizes recent developments in the IRS’s civil enforcement of the employee retention credit (ERC), with a focus on its examinations. The IRS has been active in alerting taxpayers and tax professionals regarding attempts to promote ERCs to ineligible taxpayers, recently including ERC schemes on its 2023 Dirty Dozen list (News Release IR-2023-71). Click […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, August 12, 2023

In a recent announcement, titled: “IRS cautions plan sponsors to be alert to compliance issues associated with ESOPs” (IR-2023-114, dated August 9, 2023), the Internal Revenue Service (IRS) highlighted its expanded efforts to ensure high-income taxpayers pay their fair share of taxes. The focus of this announcement is on compliance issues associated with Employee Stock […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, August 10, 2023

Introduction: The recent case of Farhy v. Commissioner has brought attention to an essential aspect of the tax collection process – the assessment authority for penalties by the Internal Revenue Service (IRS). Ed Robbins, who argued this case on behalf of the taxpayer, explains the impact of this taxpayer’s victory in the latest volume of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, August 07, 2023

In an effort to combat tax evasion and abusive tax transactions, the Internal Revenue Service (IRS) and the U.S. Treasury Department have recently released proposed regulations targeting monetized installment sale transactions. These transactions, along with substantially similar schemes, have been classified as listed transactions—a category of reportable transactions that requires special disclosure and reporting. Click […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 04, 2023

We are pleased to announce that Philipp Behrendt will be speaking at the upcoming California Lawyers Association webinar “The Use of AI for Tax Litigation,” Tuesday, August 8, 2023, 12:00 p.m. – 1:00 p.m. (PST). The webinar will delve into the transformative impact of artificial intelligence on tax litigation practices. Attendees can look forward to gaining valuable […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 01, 2023

Our partners, Dennis Perez and Sandra Brown, had the privilege of speaking in San Diego on Friday at the 8th Annual USD School of Law- RJS LAW Tax Controversy Institute.  Joining Dennis Perez on the Government Loans Panel, which provided an in depth focused on PPP, EIDL and ERC audit and fraud issues, were AUSA Dylan […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, July 28, 2023

We are pleased to announce that Steven Toscher, Michel Stein, and Philipp Behrendt will be speaking at the upcoming CalCPA webinar “Cryptocurrency Compliance 2023,” Tuesday, August 8, 2023, 9:00 a.m. – 10:00 a.m. (PST). Keep abreast of the IRS’s continuous efforts to enhance compliance in the crypto space. Join us for a practical look at the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 27, 2023

Please join us July 28, 2023 for the CalCPA 2023 Annual Income Tax Seminar. We have an excellent line up of programs – How to Help an Individuals with Unreported or Misreported Crypto Transactions(8:05 a.m. – 9:25 a.m. PST)Featuring Evan Davis R&D Credit Hot Topic and California Considerations(1:05 p.m. – 2:20 p.m. PST)Featuring Cory Stigile The […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 27, 2023

The Employee Retention Credit (ERC) has been a lifeline for businesses struggling during the COVID-19 pandemic. Designed to provide financial assistance to eligible employers who kept their workforce employed during times of economic hardship, the ERC has proven to be a vital source of support for many. However, with its increasing popularity, aggressive marketing tactics, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 26, 2023

Jonathan Kalinski quoted in Tax Notes article on newly filed Tax Court cases challenging the IRS’ position in applying IRC Section 280E to Offers in Compromise for marijuana businesses. Offers in Compromise are challenging for marijuana businesses because the IRS uses 280E disallowed expenses in determining collection potential, creating a phantom cash problem.  “The fiction of […] Read More…