TAXLITIGATOR Blog

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…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, July 24, 2023

We are pleased to announce that Steven Toscher, Michel Stein, and Sandra Brown will be speaking at the upcoming CPA Academy webinar “Tax Controversy Hot Topics,” Tuesday, July 25, 2023, 8:00 a.m. – 9:00 a.m. (PST). This webinar will cover critical practice and procedural issues facing practitioners, including IRS priorities, the new emphasis on fraud investigations, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, July 24, 2023

Please join us July 28, 2023 for the USD School of Law – RJS Law Tax Controversy Institute at the San Diego Knauss Center for Business Education, Nexus Theater University of San Diego. We have an excellent line up of programs – A Guide to IRS Criminal Tax Investigations and Prosecutions Featuring Sandra Brown IRS Cares about […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, July 21, 2023

For more than 85 years the Tax Court, its predecessor, the Board of Tax Appeals, and those courts of appeal that addressed the issue, held that the statute of limitations for filing a petition for redetermination was jurisdictional. When a prerequisite for a lawsuit is jurisdictional, it means that if the prerequisite has not been met, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 12, 2023

Puerto Rico has been offering tax incentives to wealthy individuals, hedge fund managers, and cryptocurrency traders since 2012. These tax incentives have allowed them to legally avoid paying federal income tax and certain other taxes. However, recent developments have brought these tax breaks under scrutiny, with US prosecutors and IRS agents launching criminal and civil […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, July 11, 2023

We are pleased to announce that Michel Stein, Edward Robbins, Jr. and Sandra Brown will be speaking at the upcoming CalCPA webinar “Form 8300 Reporting/Cash Intensive Business Audits,” Tuesday, July 18, 2023, 9:00 a.m. – 10:00 a.m. (PST). The law requires that trades and businesses report cash payments of more than $10,000 to the federal government […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Monday, July 10, 2023

We are very pleased to announce that Sandra R. Brown has been appointed vice chair of the Section’s Civil and Criminal Tax Penalties Committee for the 2023-2024 term. Sandra’s selection as a committee vice chair and as a Section leader represents recognition by her peers of her abilities and contributions to the work of the Section.  […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 05, 2023

The Internal Revenue Service has long had the power to issue and enforce administrative summonses for the purpose of “ascertaining the correctness of any return … determining the liability of any person for any internal revenue tax … or to collect any such liability.” See Reisman v. Caplin, 375 U.S. 440 (1964). While the courts and the […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, July 02, 2023

IRS Special Agents fanned out throughout the United States on June 30, seeking to interview promoters and clients of a “Maltese individual retirement arrangement” that for the past three years has earned a spot on the IRS’s Dirty Dozen tax promotions list. These are simply the first public actions in what will doubtless be a massive […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 22, 2023

We are pleased to announce that Michel Stein along with Caroline Ciraolo, Phillip Colasanto and Daniel Price will be speaking at the upcoming CPA Academy webinar “The Future of Voluntary Disclosures: Coming in From the Cold,“ Wednesday, June 28, 2023, 9:00 a.m. – 10:00 a.m. (PST). For more than 70 years, the IRS maintained a voluntary […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, June 21, 2023

We are pleased to announce that Michel Stein, Edward Robbins, Jr. and Robert Horwitz will be speaking at the upcoming Strafford webinar “Foreign Information Return Penalties After Farhy: Case Review and Updates, Penalty Abatements, Refund Claims,“ Tuesday, June 27, 2023, 10:00 a.m. – 11:50 a.m. (PST). The Supreme Court, in Bittner v. United States, limited the imposition […] Read More…