TAXLITIGATOR Blog

Favorable California Office of Tax Appeals Drop and Swap Decision Stands by CORY STIGILE

In 2018, Robert Horwitz posted a blog on the Appeal of Mitchell (8/2/2018), a favorable Office of Tax Appeals Opinion (the “Opinion”) that approved a “drop and swap” transaction. The FTB filed a Petition for Rehearing, which has been pending until last week when a majority Opinion on Petition for Rehearing concluded that the FTB […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and CORY STIGILE to speak on Section 199A Implementation and IRS Examination Issues: Critical QBI Issues for Individual and Business Taxpayers

We are pleased to announce that three of our principals Steven Toscher, Michel Stein, and Cory Stigile will be speaking at the upcoming Strafford webinar on Section 199A Implementation and IRS Examination Issues: Critical QBI Issues for Individual and Business Taxpayers, Tuesday, February 11, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will guide tax professionals […] Read More…

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STEVEN TOSCHER to speak at the Federal Bar Association 44th Annual Tax Law Conference, Ronald Reagan Building and International Trade Center, Washington, D.C.

We are pleased to announce that Steven Toscher, will be speaking along with Sarah E. Paul, Eversheds Sutherland, Niles Elber, Caplin & Drysdale, Thomas Curteman, Jr., Office of Chief Counsel, IRS and Hank Kea, Field Collection Operations, IRS on “Avoiding or Not Avoiding Evasion of Payment Prosecutions & the Civil Aftermath” at this year’s Federal […] Read More…

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SANDRA BROWN to speak at ABA Midyear Tax Meeting, Boca Raton Resort and Club, Florida

We are pleased to announce that Sandra Brown, will be moderating the panel  along with Jason B. Freeman, Freeman Law, Victor Jaramillo, Caplin & Drysdale, and  John Siddons, Supervisory Special Agent, Internal Revenue Service, Criminal Investigation on “A Client with Cryptocurrency Just Call – What Now?” at this year’s ABA Midyear Tax Meeting, Saturday, February […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to speak on Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Advisers

We are pleased to announce that two of our principals Steven Toscher and Michel Stein will be speaking at the upcoming Strafford webinar on Resolving Employment Tax issues: Advanced Tactics for Tax Professionals and Advisers, March 31, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will guide tax professionals and advisers on critical issues relating […] Read More…

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Estate Notches Rare Win over IRS in Penalty Refund Suit by SANDRA BROWN and TENZING TUNDEN

Enforcement and compliance is a top priority of the Internal Revenue Service (“IRS”). The IRS has 150 penalties at its disposal to assist in its stated goals of enforcement and obtaining compliance with the tax laws of the United States. Many of these penalties can be assessed not only against taxpayers but also against tax […] Read More…

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STEVEN TOSCHER, MICHEL STEIN and EVAN DAVIS to speak New Cryptocurrency Guidance: Identifying Units, Hard Forks and Airdrops

We are pleased to announce that three of our principals will be speaking at the upcoming Strafford webinar on New Cryptocurrency Guidance: Identifying Units, Hard Forks and Airdrops, January 14, 2020, 1:00 pm-2:50 pm EST, 10:00am-11:50am PST. This webinar will discuss recently released IRS Revenue Ruling 2019-24 and the updated FAQs regarding taxation of cryptocurrency. With […] Read More…

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SANDRA BROWN Quoted in Tax Analysts Article on Ride Across the Marinello Bridge Cases Could Be Bumpy

SANDRA BROWN quoted in Tax Analysts’ article, “Ride Across the Marinello Bridge Cases Could Be Bumpy.” Sandra R. Brown of Hochman Salkin Toscher Perez PC compared the bridge-case transition with the change in behavior that followed Booker v. United States, 514 U.S. 220 (2005) — the case in which the Supreme Court declared that the sentencing guidelines […] Read More…

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Revenue Procedure 2019-42: I.R.S. Provides Updated Guidance on Adequate Disclosure by SANDRA BROWN and GARY MARKARIAN

On December 2, 2019, the Internal Revenue Service released Rev. Proc. 2019-42, which applies to any income tax return filed on 2019 tax forms for the 2019 tax year, including 2019 tax forms for short taxable years beginning in 2020 if filed before the forms for 2020 are available.  This updated revenue procedure, which updates […] Read More…

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Taxpayers First by STEVEN TOSCHER, ROBERT HORWITZ and GARY MARKARIAN

the new Taxpayer First Act, among other benefits will bring the IRS into the twenty-first century. It has been more than 20 years since the U.S. Congress addressed taxpayer rights in the Tax Reform and Restructuring Act of 1998.1 In June 2019, H.R. 3151, otherwise known as the Tax payer First Act, was introduced in […] Read More…

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Hochman Salkin Toscher Perez P.C. Welcomes Associates GARABED “GARY” MARKARIAN and TENZING TUNDEN

Gary Markarian is a recent graduate of Loyola Law School’s joint J.D./ Tax LL.M. program, where he graduated with High Distinction. Prior to law school, he graduated from the University of California, Los Angeles, with a B.A. in Political Science. Gary’s prior experience includes working as a law clerk for the Law Offices of Givner & […] Read More…

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STEVEN TOSCHER, DENNIS PEREZ, MICHEL STEIN, SANDRA BROWN and JONATHAN KALINSKI to speak at the USC Gould School of Law 2020 Tax Institute, Millennium Biltmore Hotel

STEVEN TOSCHER, DENNIS PEREZ, MICHEL STEIN, SANDRA BROWN and JONATHAN KALINSKI to speak at the USC Gould School of Law 2020 Tax Institute, Millennium Biltmore Hotel

Please join us January 27-29, 2020 for the USC Gould School of Law 2020 Tax Institute at the Millennium Biltmore Hotel, Los Angeles. Learn the latest tax law developments for corporations, privately-held businesses, individuals, partnerships and real estate transactions, and important tax ethics, compliance, enforcement and estate planning solutions. Take away practical tips from over 75 veteran tax professionals […] Read More…

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