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SANDRA R. BROWN quoted in “CI Expecting More Fraud Referrals From IRS Operating Divisions”, Tax Notes

IRS CI wants more fraud referrals – from the IRS Operating Divisions. The value of the IRS’s ongoing voluntary disclosure program, both to non-compliant taxpayers and the IRS, for the goals of obtaining and encouraging tax compliance is without question.  On July 19th, Don Fort, Chief of IRS Criminal Investigation, while speaking at the University […] Read More…

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Tax Notes Quotes STEVEN TOSCHER: False Invoices Could Force Hard Choices

An attorney has many duties, including a duty of candor as well as a duty to maintain a client’s confidences, when representing a client before the IRS. On July 19th, speakers and audience members attending the University of San Diego School of Law and RJS Law Tax Controversy Institute in San Diego raised many points […] Read More…

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Ninth Circuit Holds Reckless Is Not Willful for Purposes of Preparer Penalty and Further Musings on the FBAR Willful Penalty by ROBERT HORWITZ

Internal Revenue Code § 6694 imposes a penalty on return preparers who understate a taxpayer’s tax liability.  The amount of the penalty is $1,000 per return if the understatement is due to an “unreasonable” position.  § 6694(a)(1).  Under § 6694(b)(1), the amount is the greater of $5,000 or 75% of the income derived by the […] Read More…

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SANDRA BROWN on IRS-Criminal Investigation Unit 100 Year Celebration

SANDRA BROWN on IRS-Criminal Investigation Unit 100 Year Celebration

Internal Revenue Service Criminal Investigation Division’s Los Angeles Field Office’s 100 year anniversary celebration was held on Thursday night at The Federal Bar in Long Beach. There was a huge turnout of both active and retired agents.  I was thrilled to join in the celebration, along with my partners Steve Toscher, Robert Horowitz and Cory […] Read More…

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SANDRA BROWN Quoted in Law 360 on Tax Opinions by Justice Stevens

SANDRA BROWN quoted in Law 360 article, “5 Fascinating Tax Opinions By Justice Stevens” on U.S. v Caceres case. To view full article with Sandra’s comments Click Here.

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Los Angeles Lawyer -The Impact of “Big Data” on IRS Civil and Criminal Tax Enforcement by STEVEN TOSCHER and DANIEL KELLERMAN

Much has been written over the last year concerning the lack of funding for the  Internal Revenue Service and what it means for tax enforcement.  It is well established that for every dollar spent on tax enforcement, at least four dollars are brought into the U.S. Treasury.  This makes a very compelling case for spending more—not less—on tax enforcement, […] Read More…

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AVRAM SALKIN and MICHEL STEIN to teach at upcoming PINCUS PROFESSIONAL EDUCATION Exam Prep for Tax Law Certified Specialist

We are pleased to announce that Avram Salkin and Michel Stein will be teaching at the upcoming exam preparation for the Tax Law Certified Legal Specialist Exam, August 22-23, 2019 at the Doubletree Hotel, Downtown Los Angeles. Avram Salkin will teach on August 22nd on Real Estate Taxation from 3:40 p.m. – 4:30 p.m. and Estate, Gift and Fiduciary Income Tax from […] Read More…

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STEVEN TOSCHER and MICHEL STEIN to speak on Tax Reporting of Cryptocurrency: Calculating Basis, Income and Gain

We are pleased to announce that Steven Toscher and Michel Stein will be presenting at an upcoming STRAFFORD WEBINAR: Tax Reporting of Cryptocurrency: Calculating Basis, Income and Gain.  Thursday, August 29, 2019 from 10:00 a.m. – 11:50 p.m. (PST)/1:00 p.m. to 2:50 p.m. (EDT).  For more information Click Here. This webinar will provide tax advisers […] Read More…

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JONATHAN KALINSKI to speak on Anatomy of a Tax Court Case: Litigation Tips from an Expert – July 18, 2019

We are pleased to announce that Jonathan Kalinski will be presenting at an upcoming myLawCLE /FEDERAL BAR ASSOCIATION WEBINAR: Anatomy of a Tax Court Case: Litigation Tips from an Expert  Thursday, July 18, 2019 from 4:00 p.m. – 6:00 p.m. Eastern | 3:00 p.m. – 5:00 p.m. Central | 2:00 p.m. – 4:00 p.m. Mountain […] Read More…

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BRUCE I. HOCHMAN AWARD FOR EXCELLENCE IN THE STUDY OF TAX LAW Awarded to NATHAN COX

BRUCE I. HOCHMAN AWARD FOR EXCELLENCE IN THE STUDY OF TAX LAW Awarded to NATHAN COX

We are pleased to announce the 2019 Bruce I. Hochman Award for Excellence in the Study of Tax Law was awarded to graduating UCLA Law student Nathan Cox.  The award honors the significant legacy of UCLA Law alumnus Bruce Hochman by recognizing the most outstanding graduating tax student at the law school each year.  Granted annually since its creation […] Read More…

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STEVEN TOSCHER and SANDRA BROWN to speak at upcoming Fourth Annual USD RJS Law Tax Controversy Institute, July 19, 2019

We are pleased to announce that two of our principals, Steven Toscher and Sandra Brown, the former Chief Tax prosecutor in the Central District of California, will be speaking at the upcoming 4th Annual USD School of Law RJS Law Tax Controversy Institute at University of San Diego, Joan B. Kroc Institute for Peace and […] Read More…

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SANDRA BROWN Quoted in Tax Analysts Article on IRS Data Analytics

SANDRA BROWN quoted in Tax Analysts’ article, “IRS Data Analytics Could Start Race on Voluntary Disclosures.” Sandra said the new data sets and analytics tools are allowing the IRS to make connections on its own in situations in which it used to rely on informants and use those connections to open civil and criminal investigations. […] Read More…

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