TAXLITIGATOR Blog

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 Originally enacted in the 1970s, the Bank Secrecy Act’s FBAR […] Read More…

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MICHEL STEIN and SANDRA BROWN to Speak at Upcoming NYU 81st Institute on Federal Taxation

We are pleased to announce that Michel Stein and Sandra Brown will be speaking on the following topics at the upcoming 81st Institute on Federal Taxation being held at the Westin New York, October 23-28, 2022 and Hotel Del Coronado, November 13-18, 2022. Sandra BrownOctober 23, 2022 and November 13, 2022 Michel SteinNovember 17, 2022” When Are You Crossing a […] Read More…

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MICHEL STEIN, ROBERT HORWITZ and JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar

We are pleased to announce that Michel Stein , Robert Horwitz and Jonathan Kalinski will be speaking at the upcoming Strafford webinar “Partnership Audit Adjustments Under the Centralized Audit Regime,” Wednesday, October 19, 2022, 10:00 a.m. – 11:30 a.m. (PST). This course will cover practical considerations for partners and advisers to partnerships operating under the new partnership audit regime. Our […] Read More…

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UCLA 38th Annual Tax Controversy Conference – October 27, 2022

We are pleased to let you know that the planning for the 38th Annual UCLA Extension Tax Controversy Institute is proceeding and we have an exceptional program lined up with top governmental officials and leading private practitioners from around the country.  As you know the Institute is back in person this year after two years Covid/Zoom protocols and we are […] Read More…

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EVAN DAVIS Quoted in Law360 on Justices to Review Firm’s Bid to Shield Client Tax Comms

The U.S. Supreme Court said Monday it will consider a law firm’s bid to shield client communications from grand jury subpoenas seeking documents on its tax advice in a case concerning the scope of attorney-client privilege over mixed-use legal advice. In a statement, Evan J. Davis of Hochman Salkin Toscher Perez PC, one of the […] Read More…

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EVAN DAVIS Quoted in Thomson Reuters Transparency Groups, Tax Pros Differ on Impact of Ownership Reporting Rules

Evan Davis, a veteran tax litigator with Hochman Salkin Toscher Perez PC, predicted that existing businesses, particularly limited liability companies, will find adhering to the beneficial ownership regs to be “a herculean task and will result in far less than 100% compliance.” He said many clients already fail to take the basic steps to maintain […] Read More…

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STEVEN TOSCHER, SANDRA BROWN and JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar

We are pleased to announce that Steven Toscher, Sandra Brown and Jonathan Kalinski will be speaking at the upcoming Strafford webinar “Handling Cannabis Tax Examinations: Sec. 280E, Audits, IRS Guidance,” Tuesday, October 11, 2022, 10:00 a.m. – 11:30 a.m. (PST). The sale and distribution of cannabis for recreational or medical use is a powerful economic engine generating billions in annual […] Read More…

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ROBERT HORWITZ to Receive the Joanne M. Garvey Award from the California Lawyers Association 2022 Tax Bar and Tax Policy Conference

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 EVAN DAVIS to Speak at Upcoming Spidell Webinar

We are pleased to announce that Steven Toscher, Sandra Brown and Evan Davis will be speaking at the upcoming Spidell webinar “New Corporate Transparency Act: The World is Changing,” Friday, October 7, 2022, 10:00 a.m. – 12:00 p.m. (PST). On January 1, 2021, Congress enacted the National Defense Authorization Act for Fiscal Year 2021 (NDAA). Contained within the NDAA is the Anti-Money […] Read More…

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DENNIS PEREZ, SANDRA BROWN and CORY STIGILE to Speak at Upcoming Spidell Webinar

We are pleased to announce that Dennis Perez, Sandra Brown and Cory Stigile will be speaking at the upcoming Spidell webinar “Research and Development Tax Credits: IRS Scrutiny of Qualified Research Activity and Related Expenses,” Thursday, September 29, 2022, 10:00 a.m. – 12:00 p.m. (PST). Research and development (R&D) is the lifeblood of a growing and prosperous economy, and many […] Read More…

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STEVEN TOSCHER to Speak at Upcoming CSTC Webinar

We are pleased to announce that Steven Toscher will be speaking at the upcoming CSTC 2022 Tax Forum Orange County South Chapter seminar at The Hills Hotel, Laguna Hills on “Cryptocurrency Tax Compliance: Tax Filing Requirements; Managing IRS Examinations,” Friday, September 16, 2022, 1:00 p.m. – 2:50 p.m. (PST). This course will provide tax counsel, accountants, and other advisers with a critical […] Read More…

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