TAXLITIGATOR Blog

Boechler v. Commissioner Begins a New Era in Tax Court Litigation by ROBERT HORWITZ

I am somewhat remiss in not writing sooner about the Supreme Court’s decision in Boechler, P.C. v. Commissioner, 142 S.Ct. 1493 (April 21, 2022).  It may be the most significant procedural tax case in recent years, addressing whether time deadlines in the Internal Revenue Code (in this case the deadline for filing a collection due […] Read More…

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EVAN DAVIS Quoted in Law360 on Chamber, Groups Tell Justices to Back Firm in Privilege Case

Evan Davis represents a law firm in a cutting-edge dispute about whether communications with a lawyer for both legal advice and other reasons are protected by the attorney client privilege.  This is the second legal privilege case that Evan has handled in the trial court and on appeal in the Ninth Circuit, and the present […] Read More…

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MICHEL STEIN to Speak at Upcoming CalCPA Entertainment Industry Conference

We are pleased to announce that Michel Stein along with William Abrams, Mark Pariser, and Michael Hacia will be speaking at the upcoming CalCPA Entertainment Industry Conference on “What Everyone Should Know About California Residency” on Tuesday, June 21, 2022, 8:35 a.m. – 9:35 a.m. (PST). Click Here for more information.

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MICHEL STEIN to Speak at Upcoming NYU 14th Annual Tax Controversy Forum

We are pleased to announce that Michel Stein along with Phillip Colasanto, Caroline Ciraolo, and Daniel Price will be speaking at the upcoming NYU 14th Annual Tax Controversy Forum on “Coming in From the Cold: The Future of Voluntary Disclosures” on Friday, June 24, 2022, 2:45 p.m. – 3:45 p.m. (EST). For more than 70 […] Read More…

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SANDRA BROWN to Speak at Upcoming National Association of Criminal Defense Seminar

We are pleased to announce that Sandra Brown will be speaking at the upcoming NACDL’s 2022 West Coast White Collar Conference seminar, “Only Two Things Are Certain and This Isn’t About Death: Defending Criminal Tax Cases” on Friday, June 17, 2022, 10:30 a.m. (PST) at the Kona Kai Resort & Spa, San Diego. The panel will provide an introduction to criminal […] Read More…

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ROBERT HORWITZ, CORY STIGILE and JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar

We are pleased to announce that Robert Horwitz, Cory Stigile and Jonathan Kalinski will be speaking at the upcoming Strafford webinar, “Partnership Losses in Excess of Basis: Preparing for the IRS’ New Audit Campaign” on Wednesday, June 15, 2022, 10:00 a.m. – 11:50 a.m. (PST). This webinar will prepare pass-through advisors to withstand IRS challenges […] Read More…

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EDWARD ROBBINS, JR., SANDRA BROWN and MICHEL STEIN to Speak at Upcoming Lorman Webinar

We are pleased to announce that Edward Robbins, Jr., Sandra Brown and Michel Stein will be speaking at the upcoming Lorman webinar, “Currency Transaction Report: How to File and Common Errors” on Tuesday, June 14, 2022, 10:00 a.m. – 11:05 a.m. (PST). This course will educate and assist United States persons who have the obligation […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and ROBERT HORWITZ to Speak at Upcoming CalCPA Webinar

We are pleased to announce that Steven Toscher, Michel Stein and Robert Horwitz will be speaking at the upcoming CalCPA webinar, “Understanding Opportunity Zones Tax Incentives under TCJA 2017 in the Face of New Congressional Oversight and the TIGTA Report” on Tuesday, June 7, 2022, 9:00 a.m. – 10:00 a.m. (PST). Congress is considering changes […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to Speak at Upcoming CSTC Webinar

We are pleased to announce that Steven Toscher and Michel Stein will be speaking at the upcoming CSTC San Francisco Bay Chapter webinar, “Cryptocurrency Tax Compliance: Tax Filing Requirements; Managing IRS Examinations” Wednesday, June 1, 2022, 6:00 p.m. – 8:00 p.m. (PST). This course will provide tax counsel, accountants, and other advisers with a critical […] Read More…

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

We are pleased to announce that Dennis Perez, Sandra Brown, and Cory Stigile will be speaking at the upcoming Strafford webinar, “Navigating IRS Scrutiny of R&D Tax Credits: Qualified Research Activity, Expenses, Research Credit Claims Audits” on Wednesday, June 1, 2022, 10:00 a.m. – 11:30 a.m. (PST). This CLE/CPE webinar will guide tax professionals and […] Read More…

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EVAN DAVIS Quoted in Tax Notes on Cryptocurrency

Tax Lawyers Find New Obstacles Defending Client Crypto Positions The same things that some cryptocurrency buyers like about the instrument could pose troublewhen it comes to trying to defend taxpayers in audits or court proceedings. Click Here to read full article. Cryptocurrency Holds More Curveballs for Tax Trials Blockchain technology presents an evolving area of […] Read More…

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SANDRA BROWN, EVAN DAVIS and STEVEN TOSCHER Publish Article in Los Angeles Lawyer

We are very pleased to announce that Sandra Brown, Evan Davis and Steven Toscher are featured in this month’s Los Angeles Lawyer discussing the research and development credit as applied in the entertainment industry. And you can get MCLE.  Many businesses perform some type of research and development (R&D)—the lifeblood of a growing and prosperous […] Read More…

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