TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, May 09, 2024

We are pleased to announce that on May 17, 2024, Sandra R. Brown, along with Gwen Moore (Moore Tax Law Group), Jennifer Breen (Morgan Lewis), and Pamela Grewal (Andersen Tax), will join a webinar with the Loretta Collins Argrett fellows and leadership to discuss navigating their career transitions and what it means to be a […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 08, 2024

My co-chair, Kathy Keneally and I are very pleased to ask you to save the date for the ABA 2024 Criminal Tax Fraud/Tax Controversy conference, to be held this year at the Wynn Encore on December 12-14, 2024.  The program is still in the planning stage, but we can assure you that we continue to build […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 07, 2024

We are pleased to announce that Steven Toscher, Michel R. Stein and Evan Davis will be speaking at the upcoming Strafford webinar “Cryptocurrency Tax Compliance: Tax Filing Requirements, Managing IRS Examinations” Thursday, May 9, 2024, 10:00 a.m. – 11:30 a.m. (PST). The IRS continues to press its concern over “massive under-reporting” of income from cryptocurrency transactions, including […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 06, 2024

Steven Toscher, the managing principal for Hochman Salkin Toscher Perez P.C., has received the Jules Ritholz Memorial Merit Award from The American Bar Association’s (ABA) Tax Section Civil and Criminal Tax Penalties Committee. The award was presented during ABA’s 2024 May Tax Meeting, held in Washington, DC. on May 3, 2024.  Click Here to Read […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, May 02, 2024

We are pleased to announce that Jonathan Kalinski and Philipp Behrendt of our firm participated in the California Lawyers Association – Taxation Section’s Washington, D.C. Delegation on April 30 and May 1, 2024. For over 30 years, the Taxation Section has annually selected a delegation to advocate for California tax lawyers’ ideas and proposals to […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 01, 2024

The IRS published the first draft of the 1099-DA with supplementary information on 4/22/2024 (89 FR 29433). The Form 1099-DA will be used by digital asset brokers to report transactions of US taxpayers, similar to the Form 1099-DIV brokers and banks issue every year. Back in November 2021, the Infrastructure Investment and Jobs Act (“IIJA”) […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, April 26, 2024

We are pleased to announce that Sandra R. Brown will be moderating a panel at the upcoming ABA Tax Section 2024 May Tax Meeting on the on the topic of “The Importance of Interview Notes in Criminal Matters, From Investigation Through Sentencing” on Saturday, May 4, 2024, 10:30 a.m. (EST), along with co-panelists, Michael Kelly (Akerman […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, April 25, 2024

Philipp Behrendt was quoted in Tax Notes Article on the question whether the IRS get a percentage after a crypto 51 percent attack (Posted on Apr. 16, 2024, by Nathan J. Richman and Mary Katherine Browne). The article explores the question whether the IRS position on the worthlessness of digital asset is applicable to losses […] Read More…

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…

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…

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…

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…