TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 18, 2021

On May 17, 2021, the Supreme Court issued its unanimous opinion in CIC Services, Inc. v. Internal Revenue Service, holding that a suit challenging an IRS Notice regarding micro-captive insurance companies was not barred by the Anti-Injunction Act (“AIA”).[1]  We’ll start with some background.  The AIA was enacted shortly after the Civil War, in the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 17, 2021

You can go on YouTube and watch the greatest dunks, home runs, touchdowns over and over and over and not pay a cent.  How much would you pay to “own” that highlight?  For many the answer is tens or hundreds of thousands.  NBA Top Shot is officially licensed by the NBA and in little time […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, May 17, 2021

We are pleased to announce that Dennis Perez, Michel Stein, and Robert Horwitz will be speaking at the upcoming CalCPA webinar, “Federal and State Residency Issues: Remote Workers and Navigating IRS Examination Guidance and State Regulations in the Post-Covid-19 World” on Tuesday, May 25, 2021, 9:00 a.m. – 10:00a.m. (PST).   This webinar will guide […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 11, 2021

We wanted to express our appreciation to the Tax Court trial team responsible for the Estate of Michael Jackson prevailing in its long running Estate tax dispute with the IRS. A big win for the Estate reducing the IRS asserted tax liability by hundreds of millions of dollars. In addition to Avram Salkin, Steven Toscher, Robert […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, May 11, 2021

We are pleased to announce that Evan Davis has been elected as Fellow by the American College of Tax Counsel. Evan, a principal of our firm, joined us in 2016, after more than 20 years in the public sector as a trial lawyer with extensive civil and criminal trial and appellate experience in both federal and state […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Saturday, May 08, 2021

We are pleased to invite you to the  13th Annual NYU Tax Controversy Forum Webinar to be held June 24 and 25.  You do not want to miss this program. Co-Chairs Bryan Skarlatos and Steven Toscher are pleased to announce this year’s NYU Tax Controversy Forum which will feature updates on what the IRS is doing to enhance compliance through communication and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 05, 2021

On this week’s podcast, we’re chatting about cryptocurrency and enforcement. Joining the conversation is Michel Stein and Steven Toscher, who have previously participated before. If you’re a longtime listener, then you know it’s been more than 60 episodes since their last visit. Yet, whenever cryptocurrency and enforcement are hot topics of conversation, we happily strive […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, May 05, 2021

Richard and Kimberly Gaetano owned marijuana dispensaries.  After a falling out with their legal advisor/business partner, he apparently ratted them out to IRS Criminal Investigations (“CI”).  In 2017, they sued to bar CI from discussing attorney-client matters with their former legal advisor.  That case was dismissed. Gaetano v United States, 942 F.3d 727 (6th Cir. […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 28, 2021

Why is it that tax compliance involving this emerging asset continues to be problematic?  Aside from any individualized taxpayer’s confusion or potential motivations, one additional answer may be the direct result of the lack of third-party reporting requirements.  While digital currency exchanges, under Title 31 and the Bank Secrecy Act, are generally regulated as money […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, April 23, 2021

We are pleased to announce that Steven Toscher, Michel Stein, and Robert Horwitz will be speaking at the upcoming Spidell webinar, “Federal and State Residency Issues: Remote Workers and Navigating IRS Examination Guidance and State Regulations in the Post-Covid-19 World” on Wednesday, May 5, 2021, 10:00 a.m. – 12:00 p.m. (PST). This webinar will cover […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, April 21, 2021

A recently released IRS legal memorandum appears to be intended to clarify inventory tax accounting principles for state-legal marijuana businesses despite not mentioning the restriction they face, according to practitioners. Jonathan Kalinski of Hochman Salkin Toscher Perez PC told Tax Notes in part that “Most taxpayers aren’t asking to capitalize costs to inventory and would rather […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, April 19, 2021

We are pleased to announce that Dennis Perez and Steven Toscher will be speaking at the upcoming Jewish Community Foundation of Los Angeles webinar, “The (Tax) Truths and Consequences of Leaving California” on Wednesday, April 28, 2021, 12:00 p.m. – 1:30 p.m. (PST). This webinar will guide tax professionals and advisers on the latest California […] Read More…